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ESTATE OF SCHAEFER v. COMMISSIONER

Docket No. 13183-11.

145 T.C. 134 (2015)

ESTATE OF ARTHUR E. SCHAEFER, DECEASED, KATHLEEN J. WELLS, EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 28, 2015.

Attorney(s) appearing for the Case

Robert J. Onda , for petitioner.

Richard J. Hassebrock and Emily J. Giometti , for respondent.

OPINION

This case involves an estate that seeks a charitable contribution deduction for the values of remainder interests in two charitable remainder trusts created during the decedent's life. Each trust instrument states that the trustee must make distributions to the noncharitable beneficiary of the lesser of the net trust...

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