Estate of Edgar v. Commissioner

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.