ESTATE OF BROOKS v. COMMISSIONER

Docket No. 55269.

27 T.C. 295 (1956)

ESTATE OF CHARLES A. BROOKS, DECEASED, PEOPLES FIRST NATIONAL BANK & TRUST CO., ET AL., EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 16, 1956.


Attorney(s) appearing for the Case

Mahlon E. Lewis, Esq., for the petitioners.

George J. Rabil, Esq., for the respondent.


In this proceeding estate taxes in the total amount of $45,974.14 are in controversy. A deficiency of $30,983 was determined by respondent and, in amended pleadings, he claims an additional liability of $14,991.14. The only issue is whether, in computing the deduction for charitable bequests, the amount of the residuary estate transferred to a testamentary trust is allowable in full or is to be reduced by an amount representing a contingent liability for State inheritance...

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