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ESTATE OF HUBERT v. COMMISSIONER

Docket No. 22333-90.

66 T.C.M. 1064 (1993)

T.C. Memo. 1993-482

Estate of Otis C. Hubert, Deceased, C&S/Sovran Trust Company (Georgia), N.A., A National Banking Association, Co-Executor, v. Commissioner.

United States Tax Court.

Filed October 19, 1993.

Attorney(s) appearing for the Case

David W. Aughtry, 233 Peachtree St., Atlanta, Ga., James M. McCarten, and David W. Seigel, for the petitioner. Willard N. Timm, Jr., for the respondent.

Memorandum Opinion

CLAPP, Judge:

Respondent determined a deficiency in petitioner's estate tax in the amount of $14,052,146. The issue for decision is whether the bequests in the amount of $100,000 each to two subtrusts providing for the support of the missionary work of charitable organizations through two named individuals and for the establishment of foreign mission field medical clinics qualify for a charitable deduction.1

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