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ESTATE OF SPEER v. COMMISSIONER

Docket No. 3346-69.

57 T.C. 804 (1972)

ESTATE OF GEORGE I. SPEER, DECEASED, BANK OF DELAWARE AND ALICE M. SPEER, EXECUTORS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 15, 1972.

Attorney(s) appearing for the Case

Howard L. Williams and Daniel L. Twer, for the petitioners.

Albert J. O'Connor, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined a deficiency in petitioners' estate tax in the amount of $510,195.19. The sole issue for our determination is whether the remainder interest in a trust established by the decedent fails to qualify for a charitable deduction pursuant to section 20551 because of the management discretion vested in the trustee.

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