Memorandum Findings of Fact and Opinion
The respondent has determined a deficiency of $18,397.23 in the petitioner's estate tax liability. The deficiency results from the disallowance by the respondent of a charitable deduction of $67,118.99 claimed in the estate tax return.
The issue is whether provisions of a testamentary trust giving the trustee power to invade the principal of the trust estate if, in his judgment, the income of the trust proved insufficient...
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