Legal Opinion

Estate of Leeds v. Commissioner

United States Tax Court

Decided April 16, 1970No. Docket Nos. 396-69, 397-69Published

1. The order of abatement of bequests under decedent-husband's will determined for the purpose of computing the marital deduction under sec. 2056, I.R.C. 1954. 2. Bequests to the trustees of the Palladium Fund to be used primarily as a pension, unemployment, and insurance fund for the employees of the Palladium-Item, a newspaper, and the wives and minor children of such employees are not deductible under sec. 2055, I.R.C. 1954, as "charitable" bequests.

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1. The order of abatement of bequests under decedent-husband's will determined for the purpose of computing the marital deduction under sec. 2056, I.R.C. 1954. 2. Bequests to the trustees of the Palladium Fund to be used primarily as a pension, unemployment, and insurance fund for the employees of the Palladium-Item, a newspaper, and the wives and minor children of such employees are not deductible under sec. 2055, I.R.C. 1954, as "charitable" bequests. Estate of Leonard O. Carlson, 21 T.C. 291 (1953), overruled.

1Opinion of the Court

Estate of Rudolph G. Leeds, The Second National Bank of Richmond, Executor, Petitioner v. Commissioner of Internal Revenue, Respondent; Estate of Florence Smith Leeds, The Second National Bank of Richmond, Executor, Petitioner v. Commissioner of Internal Revenue, Respondent

Estate of Leeds v. Commissioner

Docket Nos. 396-69, 397-69

United States Tax Court

54 T.C. 781; 1970 U.S. Tax Ct. LEXIS 162;

April 16, 1970, Filed

Decisions will be entered under Rule 50.

1. The order of abatement of bequests under decedent-husband's will determined for the purpose of computing the marital deduction under sec.…

2Cases cited5 opinions

  1. Riggs v. Del DragoSupreme Court of the United States · 1942
  2. Gimbel v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1931
  3. Watson v. United StatesCourt of Appeals for the Third Circuit · 1965
  4. Estate of Carlson v. CommissionerUnited States Tax Court · 1953
  5. Estate of Leeds v. CommissionerUnited States Tax Court · 1970

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