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ESTATE OF ATKINSON v. C.I.R.

No. 01-16536.

309 F.3d 1290 (2002)

ESTATE OF Melvine B. ATKINSON, Deceased, Christopher J. MacQuarrie, Executor, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

October 16, 2002.

Attorney(s) appearing for the Case

David DeCoursey Aughtry, Charles E. Hodges, II, Chamberlain, Hrdlicka, White, Williams & Martin, Atlanta, GA, for Petitioners-Appellants.

Jonathan S. Cohen, Steven Parks, Anthony T. Sheehan, Dept. of Justice, App. Tax Div., Washington, DC, for Respondent-Appellee.

Before BIRCH and COX, Circuit Judges, and GEORGE, District Judge.

BIRCH, Circuit Judge:

In this tax appeal, we determine whether the failure of an estate to comply with tax regulations regarding annual disbursements from a charitable remainder annuity trust results in the complete denial of a charitable deduction, even when a substantial amount of money would flow to charity. The Tax Court held that no charitable deduction was allowable. Because the law is clear, we AFFIRM.

I...

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