Estate of Edgar v. Commissioner

74 T.C. 983 (1980)

From our private database of 46,500+ case briefs, written and edited by humans—never with AI.

Estate of Edgar v. Commissioner

United States Tax Court
74 T.C. 983 (1980)

Facts

When Clara Edgar died, her will transferred her entire estate to a trust set up by her deceased sister, Jean Vaughan. The trust’s income would first be distributed to four individuals in specified monthly amounts for life. The trust’s remaining income would be distributed to multiple organizations that all qualified for charitable deductions under 26 U.S.C. § 2055. At the time of Edgar’s death, the principal in Vaughan’s trust already generated enough income to make the monthly payments to the individual life tenants. When Edgar’s estate (plaintiff) filed its federal estate tax return, it deducted the entire amount that it had transferred into the trust. The estate claimed that, as a practical matter, none of Edgar’s estate would be needed to make the monthly payments to the nonqualifying individual recipients. Thus, Edgar’s entire transfer would be used only to make payments to the qualifying charities and was deductible. Alternatively, the estate argued that the monetary value of the individuals’ life estates could be ascertained using actuarial tables (that estimated the individuals’ likely lifespans). The estate was willing to sever that ascertainable, noncharitable amount from the overall asset transfer and pay estate taxes on that portion. The federal government (defendant) denied the estate any charitable deduction. The estate petitioned for a determination that it could claim a partial or full charitable deduction.

Rule of Law

Issue

Holding and Reasoning (Irwin, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 832,000 law students since 2011. Some law schools even subscribe directly to Quimbee for all their law students.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

Here's why 832,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,500 briefs, keyed to 994 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 832,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,500 briefs - keyed to 994 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership