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Held: Trust assets worth approximately $617,317
at D’s date of death are includable in the gross estate
on account of absence of a disclaimer qualified within
the meaning of sec. 2518, I.R.C.
Held, further, no charitable deduction is
allowable with respect to distributions to the American
Cancer Society, Yale University School of Law, or the
State of Israel.
Richard V. Vermazen, for petitioner.
Christine V. Olsen, for respondent.
OPINION
WHERRY, Judge: Respondent determined a Federal estate tax
deficiency of $356,211 for the Estate of Leona Engelman (the
estate). After concessions, the issues for decision are:
(1) Whether a qualified disclaimer within the meaning of
section 2518 was made with respect to trust assets worth
approximately $617,317 at the date of death of Leona Engelman
(decedent); and
(2) whether, to the extent that the foregoing trust assets
are included in the gross estate, the estate is entitled to a
charitable deduction for certain amounts distributed.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the date of decedent’s
death, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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Last modified: May 25, 2011