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ESTATE OF WOODWORTH v. COMMISSIONER

Docket No. 1953-65.

47 T.C. 193 (1966)

ESTATE OF AMELIA B. WOODWORTH, DECEASED, CITIZENS & SOUTHERN NATIONAL BANK OF SOUTH CAROLINA AND LEONARD BECKER, JR., EXECUTORS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 23, 1966.

Attorney(s) appearing for the Case

T.E. Walsh, for the petitioners.

Thomas A. Brown, for the respondent.

OPINION

DAWSON, Judge:

Respondent determined a deficiency in estate tax against the petitioners in the amount of $27,706.60.

Some adjustments made in the notice of deficiency were not contested by petitioners. The only issue for decision is whether the petitioners are entitled to a charitable deduction of $180,904.14 by reason of a devise in the decedent's residuary estate.

All of the facts have been stipulated by the parties and are...

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