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ESTATE OF THAYER v. COMMISSIONER

Docket No. 48059.

24 T.C. 384 (1955)

ESTATE OF PHILIP R. THAYER, DECEASED, ANNA-MARY THAYER, ERNEST W. JACKSON, AND CROCKER FIRST NATIONAL BANK OF SAN FRANCISCO, EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 14, 1955.

Attorney(s) appearing for the Case

Clarence E. Musto, Esq., for the petitioners.

Aaron S. Resnik, Esq., for the respondent.

This proceeding involves a deficiency in estate tax in the amount of $26,341.48. The estate tax return was filed with the collector of internal revenue at San Francisco, California. Certain adjustments are uncontested. The sole issue presented for decision is whether a legacy by the decedent to California Alumni Association is deductible from the gross estate under section 812 (d) of the Internal Revenue Code of 1939. A stipulation of facts was filed and oral testimony and...

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