- 24 - means the person to whom a power of appointment is given or in whose favor a power of appointment is reserved.”). D. Conclusion We conclude that decedent’s execution of the document entitled “POWER OF APPOINTMENT”, which became effective upon and by reason of her death, constituted an acceptance of the property in Trust A within the meaning of section 2518. Consequently, the later attempted disclaimer by her executor was not qualified for Federal estate tax purposes. The trust assets of approximately $617,317 that were the subject of the disclaimer are therefore includable in decedent’s gross estate. II. Deductions From the Gross Estate for Charitable Gifts A. General Rules Section 2055(a) provides a deduction from the gross estate for the value of bequests, legacies, devises, or transfers to, inter alia, (1) the United States or a political subdivision thereof, for public purposes; (2) corporations organized and operated exclusively for religious, charitable, scientific, literary, or educational purposes; and (3) trustees or fraternal organizations, but only if the gifts are to be used exclusively for religious, charitable, scientific, literary, or educational purposes. Sec. 2055(a)(1), (2), and (3). Federal courts have construed gifts to foreign political units, when clearly restricted to charitable purposes, as gifts in trust within thePage: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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