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ESTATE OF CHRISTIANSEN v. C.I.R.

No. 08-3844.

586 F.3d 1061 (2009)

ESTATE OF Helen CHRISTIANSEN, Deceased, Christine Christiansen Hamilton, Personal Representative, Petitioner-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Eighth Circuit.

Filed: November 13, 2009.

Attorney(s) appearing for the Case

John W. Porter, argued, Keri D. Brown, Baker Botts L.L.P., Houston, TX, for Petitioner-Appellee.

Bethany B. Hauser, argued, Teresa E. McLaughlin, on the brief, Washington, DC, for Respondent-Appellant.

Before MELLOY, BEAM, and GRUENDER, Circuit Judges.

MELLOY, Circuit Judge.

The Tax Court1 held that a partial disclaimer was valid at least as to an amount that subsequently passed to a foundation that Helen Christiansen ("Christiansen") named as a contingent beneficiary in her will. The Tax Court also held that Christiansen's estate was entitled to a charitable deduction for this amount. The Commissioner of Internal Revenue appeals, and we affirm...

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