Memorandum Findings of Fact and Opinion
SMITH, Judge:
This proceeding involves an estate tax deficiency of $16,260.15. The sole question for our determination is whether a bequest by decedent to trustees for charitable purposes of the remainder of her residuary estate, after a life estate to her niece, was a charitable bequest the value of which is deductible from gross income under section 812(d) of the Internal Revenue Code.
Several additional...
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