Memorandum Findings of Fact and Opinion
HOYT, Judge:
The respondent determined a $123,341.71 deficiency in the estate tax for the Estate of William Zentmayer. The Commissioner disallowed a charitable deduction for the bequest of a remainder interest in the principal of the testamentary trust on the grounds that since there was no ascertainable standard which limited the trustees' invasion of principal, the value of the charitable bequest was not determinable...
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