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ESTATE OF SCHOONMAKER v. COMMISSIONER

Docket No. 5695.

6 T.C. 404 (1946)

ESTATE OF JAMES M. SCHOONMAKER, JR., DECEASED, THE UNION TRUST COMPANY OF PITTSBURGH, EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 8, 1946.

Attorney(s) appearing for the Case

Norman D. Keller, Esq., for the petitioner.

Homer F. Benson, Esq., for the respondent.

OPINION.

SMITH, Judge:

The respondent has determined a deficiency of $138,771.69 in the estate tax of the estate of James M. Schoonmaker, Jr., deceased. The principal question in issue is whether the estate is entitled to deduct as a charitable bequest the value of the remainder of a trust estate, the income from which is to go to certain named charities after the death of decedent's widow, who is a life beneficiary with the right to invade the trust...

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