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BURDICK v. C.I.R.

No. 91-70429.

979 F.2d 1369 (1992)

Thomas BURDICK, Executor; Estate of Perrin V. Burdick, Petitioners, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent.

United States Court of Appeals, Ninth Circuit.

Decided November 18, 1992.

Attorney(s) appearing for the Case

Edward O.C. Ord, San Francisco, Cal., for petitioners.

Sara S. Holderness, Dept. of Justice, Washington, D.C., for respondent.

Before TANG, PREGERSON and ALARCON, Circuit Judges.

TANG, Circuit Judge:

The estate of Perrin V. Burdick ("Taxpayer") appeals the tax court's denial of its $60,000 charitable deduction. Taxpayer challenges the tax court's finding that it terminated the nondeductible split-interest charitable bequest ("split-interest") solely to gain a charitable deduction. Taxpayer also argues that when it terminated the split-interest, the split-interest rules no longer applied. We affirm...

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