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ESTATE OF HOSKINS v. COMMISSIONER

Docket No. 9772-77.

71 T.C. 379 (1978)

ESTATE OF EDMUND S. HOSKINS, DECEASED, MERCANTILE-SAFE DEPOSIT & TRUST COMPANY, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 14, 1978.

Attorney(s) appearing for the Case

Jacques T. Schlenger, Harry D. Shapiro, and Bryson L. Cook, for the petitioner.

Dale Eggleston, for the respondent.

OPINION

DAWSON, Judge:

Respondent determined a deficiency of $22,470.82 in the Federal estate tax of the Estate of Edmund S. Hoskins.

The only issue remaining for decision is whether a charitable deduction for a remainder interest to be appointed to charity is allowable under section 2055(b)(2),1 notwithstanding the fact that the transfer to the charity fails to meet the provisions of section 2055(e)(2)(A) which...

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