Estate of Leona Engelman, Deceased, Peggy D. Mattson, Executor - Page 24

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          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 the             






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