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ESTATE OF BOESHORE v. COMMISSIONER

Docket No. 6777-80.

78 T.C. 523 (1982)

ESTATE OF MINNIE L. BOESHORE, DECEASED, LINCOLN NATIONAL BANK & TRUST COMPANY OF FORT WAYNE AND MELVIN V. EHRMAN, EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 31, 1982.

Attorney(s) appearing for the Case

Stephen J. Williams, for the petitioners.

Elsie Hall, for the respondent.

OPINION

FAY, Judge:

Respondent determined a deficiency of $101,358.53 in the Federal estate tax of the Estate of Minnie L. Boeshore. After concessions, the issues are (1) whether a deduction is allowable for the present value of a certain charitable unitrust interest created by a testamentary trust, and (2) the correct actuarial computation of the present value of a charitable remainder interest created by a separate inter vivos trust.

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