ESTATE OF BUTLER v. COMMISSIONER

Docket No. 32431.

18 T.C. 914 (1952)

ESTATE OF NICHOLAS MURRAY BUTLER, DECEASED, T. LUDLOW CHRYSTIE AND GUARANTY TRUST COMPANY OF NEW YORK, SURVIVING EXECUTORS, AND T. LUDLOW CHRYSTIE AND GUARANTY TRUST COMPANY OF NEW YORK, EXECUTORS OF THE ESTATE OF KATE BUTLER, DECEASED EXECUTRIX, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated August 27, 1952.


Attorney(s) appearing for the Case

Samuel L. Brookfield, Esq., for the petitioners.

Ellyne E. Strickland, Esq., for the respondent.


The respondent determined a deficiency of $650.39 in estate tax of the estate of Nicholas Murray Butler. The entire deficiency is in dispute and petitioners claim an overpayment of approximately $14,500. Two minor issues have been stipulated by the parties in favor of the petitioners. The remaining questions presented are as follows:

1. Is the full amount of a specific bequest to a charitable legatee deductible under section 812 (d) of the Internal Revenue Code where...

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