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ESTATE OF CHRISTIANSEN v. COMMISSIONER

No. 15190-05.

130 T.C. 1 (2008)

ESTATE OF HELEN CHRISTIANSEN, DECEASED, CHRISTINE CHRISTIANSEN HAMILTON, PERSONAL REPRESENTATIVE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

January 24, 2008.

Attorney(s) appearing for the Case

John W. Porter and J. Graham Kenney, for the estate. Trent D. Usitalo, for respondent.

HOLMES, Judge:1

Helen Christiansen's will left everything to her only child, Christine Hamilton. The will anticipated that Hamilton would disclaim a part of her inheritance, and directed that any disclaimed property would go in part to a charitable trust and in part to a charitable foundation that Christiansen had established. The trust would last for 20 years, and pay an annuity of 7 percent...

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