Booher v. United States

363 F. Supp. 730, 33 A.F.T.R.2d (RIA) 1379, 1973 U.S. Dist. LEXIS 11943
CourtDistrict Court, S.D. Ohio
DecidedSeptember 12, 1973
DocketCiv. No. 4236
StatusPublished

This text of 363 F. Supp. 730 (Booher v. United States) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Booher v. United States, 363 F. Supp. 730, 33 A.F.T.R.2d (RIA) 1379, 1973 U.S. Dist. LEXIS 11943 (S.D. Ohio 1973).

Opinion

CARL B. RUBIN, District Judge.

This matter is before the Court upon an Agreed Statement of Facts and upon briefs filed by the parties. In accordance with Rule 52 of the Federal Rules of Civil Procedure, the following Findings of Fact and Conclusions of Law are filed.

I. FACTS

1. On January 21, 1955, the decedent, Harry W. Booher, executed an Indenture of Trust. He died November 14, 1967. As executrix, Ruby E. Booher timely filed a federal estate tax return for the decedent’s estate and paid the tax due thereon ($4,688.97). The estate claimed a deduction of $135,628.00 for a charitable remainder interest in the decedent’s trust under § 2055(a) of the Internal Revenue Code of 1954, 26 U.S.C. § 2055(a)(2) (1967).

2. The Internal Revenue Service disallowed the claimed deduction and assessed a deficiency of $54,522.521 together with an assessment for interest in the amount of $7,231.33. The assessed deficiency and interest were paid by the Booher Estate on or about May 7, 1971, and on July 21, 1971, the Estate timely filed a claim for refund. Such claim was disallowed by the District Director of Internal Revenue Service at Cleveland, Ohio.

3. While the trust was created inter vivos, it survived the settlor’s death with elective income to Ruby E. Booher, widow. A failure of the widow to elect income by February 15 of each year would cause such income to be divided between Wheaton College and Moody Bible Institute.2

4. Section 7 of the Indenture of Trust provides in part as follows:

In case, in the opinion of my wife, Ruby E. Booher, an emergency arises as the result of which her support and needs cannot be adequately met with the use of funds or income of her own, increased by income from this trust, then she may withdraw and the Trustees shall deliver to her, upon her written request, such amounts out-of the principal of this Trust as shall be necessary when added to other available funds to meet her then needs. Her statement in such written request to the Trustee, as to the existence of the needs and the amount required to meet them shall be sufficient justification for the Trustee to permit withdrawal from principal under this clause.

5. § 2055 of the Internal Revenue Code of 1954, 26 U.S.C. § 2055 (1967), in effect at the decedent’s death, stated:

(a) In general. — For purposes of the tax imposed by section 2001, the value of the taxable estate shall be de[732]*732termined by deducting from the value of the gross estate the amount of all bequests, legacies, devises, or transfers. . .
(2) to or for the use of any corporation organized and operated exclusively for religious, charitable, scientific, literary or educational purposes, including the encouragement of art and the prevention of cruelty to children or animals, no part of the net earnings of which inures to the benefit of any private stockholder or individual, and no substantial part of the activities of which is carrying on propaganda, or otherwise attempting, to influence legislation; . . .

6. The applicable Estate Tax Treasury Regulation 3 § 20.2055-2, 26 C.P.R. § 20.2055-2 (1973) is as follows:

(a) Remainders and similar interests. If a trust is created or property is transferred for both a charitable and a private purpose, deduction may be taken of the value of the charitable beneficial interest only insofar as that interest is presently ascertainable, and hence severable from the non-charitable interest. The present value of a remainder or other deferred payment to be made for a charitable purpose is to be determined in accordance with the rules stated in § 20.2031-7. Thus, if money or property is placed in trust to pay income to an individual during his life, or for a term of years, and then to pay the principal to a charitable organization, the present value of the remainder is deductible. .
(b) Transfers subject to a condition or a power. If, as of the date of a decedent’s death, a transfer for charitable purposes is dependent upon the performance of some act or the happening of a precedent event in order that it might become effective, no deduction is allowable unless the possibility that the charitable transfer will not become effective is so remote as to be negligible. If an estate or interest has passed to or is vested in charity at the time of decedent’s death and the estate or interest would be defeated by the performance of some act or the happening of some event, the occurrence of which appeared to have been highly improbable at the time of the decedent’s death, the deduction is allowable. If the legatee, devisee, do-nee, or trustee is empowered to divert the property or fund, in whole or in part, to a use or purpose which would have rendered it, to the extent that it is subject to such power, not deductible had it been directly so bequeathed, devised, or given by the decedent, the deduction will be limited to that portion, if any, of the property or fund which is exempt from an exercise of the power. The deduction is not allowed in the case of a transfer in trust conveying to charity a present interest in income if by reason of all the conditions and circumstances surrounding the transfer it appears that the charity may not receive the beneficial enjoyment of the interest.

II. OPINION

A determination of taxability or nontaxability requires the following inquiry :

(1) is the power to invade the trust corpus in terms of a measurable and ascertainable standard, and (2) if a fixed standard is ascertainable, is the possibility of invasion remote enough to insure the charitable remaindermen will, in all likelihood, take an actuarially calculable amount? Humes v. United States, 276 U.S. 487 [48 S.Ct. 347, 72 L.Ed. 667] (1928); Ithaca Trust Co. v. United States, 279 U.S. 151 [49 S.Ct. 291, 73 L.Ed. 647] (1929); Merchants National Bank v. Commissioner, 320 U.S. 256 [64 S.Ct. 108, 88 L.Ed. 35] (1943); Henslee v. [733]*733Union Planters National Bank & Trust Co., 335 U.S. 595 [69 S.Ct. 290, 93 L.Ed. 259] (1949).

The Supreme Court has twice, under this two-pronged test, denied charitable deductions. A right of a trustee to invade corpus “for the comfort, support, maintenance, and/or happiness of my said wife, and it is my wish and will that in the exercise of its discretion with reference to such payments from the principal of the trust fund to my said wife, May L.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Humes v. United States
276 U.S. 487 (Supreme Court, 1928)
Ithaca Trust Co. v. United States
279 U.S. 151 (Supreme Court, 1929)
Merchants Nat. Bank of Boston v. Commissioner
320 U.S. 256 (Supreme Court, 1943)
Henslee v. Union Planters National Bank & Trust Co.
335 U.S. 595 (Supreme Court, 1949)
Blodget v. Delaney, Collector
201 F.2d 589 (First Circuit, 1953)
Mercantile-Safe Deposit and Trust Co. v. United States
252 F. Supp. 191 (D. Maryland, 1966)
Title Insurance and Trust Company v. United States
249 F. Supp. 386 (S.D. California, 1965)

Cite This Page — Counsel Stack

Bluebook (online)
363 F. Supp. 730, 33 A.F.T.R.2d (RIA) 1379, 1973 U.S. Dist. LEXIS 11943, Counsel Stack Legal Research, https://law.counselstack.com/opinion/booher-v-united-states-ohsd-1973.