Commissioner of Internal Rev. v. MacAulay's Estate

150 F.2d 847, 34 A.F.T.R. (P-H) 106, 1945 U.S. App. LEXIS 4196
CourtCourt of Appeals for the Second Circuit
DecidedJuly 24, 1945
Docket299
StatusPublished
Cited by11 cases

This text of 150 F.2d 847 (Commissioner of Internal Rev. v. MacAulay's Estate) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commissioner of Internal Rev. v. MacAulay's Estate, 150 F.2d 847, 34 A.F.T.R. (P-H) 106, 1945 U.S. App. LEXIS 4196 (2d Cir. 1945).

Opinion

AUGUSTUS N. HAND, Circuit Judge.

On April 20, 1938, the testatrix, Mrs. Macaulay, made a gift to her husband of 5,000 shares of first preferred stock of Niagara Hudson Power Corporation, and on July 1, 1938, of certain house furnishings and art objects. At the time of her death, which was November 24, 1938, the stock had a fair market value of $428,750. Gift taxes were paid on the foregoing donations. In October 1937 Mrs. Macaulay *848 made a will in which she bequeathed to her husband a legacy of $1,000,000. At about the same time she told Governor Nathan L. Miller, her legal adviser and one of the executors named in her will, that she was thinking of giving her husband securities in an amount sufficient to yield an income of $25,000 per year so that he could meet the additional expenses he was under because of his official position as Irish Envoy to the Vatican. The stock of the Niagara Hudson Power Corporation was apparently given to fulfil the expectations she had expressed but there was no indication that she intended the gift as an advancement on account of the $1,000,000 bequest to her husband. Nevertheless, at the suggestion of Governor Miller, the gift of stock was treated in the judicial accounting in the Surrogate’s Court as an advance of $400,-000 upon the $1,000,000 legacy and the balance, that is $600,000, was accepted by Mr. Macaulay as a full discharge of the entire bequest on the part of the executors. Under the Seventh or residuary clause of her will the decedent gave 46% of her residuary estate to various charities and in Article V of the Seventh Qause provided as follows:

“V. In the event of the death before my decease, or the incapacity to take, of any legatee hereinbefore mentioned, or of the invalidity or ineffectiveness for any reason of any bequest hereinbefore made, for which eventuality no other or different provision shall have been made, I give, devise and bequeath the share, shares or sum so attempted to be bequeathed, to the survivors and to the corporations having capacity to take at the time of my decease of those mentioned as legatees in this “Seventh” paragraph or residuary clause of my Will in proportion to the number of shares of my residuary estate given and bequeathed to each respectively as aforesaid.”

The executors in setting forth the amount of charitable deductions in their estate tax return included the amount represented by the disclaimed legacy of $400,000 in the residuary estate, 46’% of which, as we have already said, was bequeathed to charity. This was due to the advice of Governor Miller, probably founded on the following provision of decedent’s will:

“ * * * I may * * * make advances to some of the legatees herein named on account of their said legacies, and to the extent that I may make such advances, I direct that all legacies upon which advances shall have been made by me shall to the extent thereof abate.”

The executors filed their estate tax return on February 20, 1940, and the Commissioner assessed the tax upon the theory that the gift of stock which the decedent made to her husband was in contemplation of death and hence was to be treated as part of her estate for tax purposes. The Tax Court rejected the theory that the gift was made in contemplation of death. In spite of the treatment of it as an advancement before the Surrogate, it was held that it was not an advancement and this holding was in accordance with the New York law as established in Bowron v. Kent, 190 N.Y. 422, 83 N.E. 472, and Matter of Farmers’ Loan & Trust Co., 181 App.Div. 642, 168 N.Y.S. 952, affirmed 225 N.Y. 666, 122 N.E. 880. The Tax Court required recomputation of the tax in accordance with the opinion.

Upon disclaimer by the legatee of $400,-000 of his legacy, the $400,000 passed into the residuary estate, 46% of which was devised to charity: The taxpayer’s recomputation of the tax, which was accepted by the Tax Court, treated 46% of the $400,000 disclaimed as exempt from the taxable estate as a charitable bequest. The Tax Court’s final order determined that the executors had made an overpayment of $109,682.89, doubtless upon the theory that the disclaimer related back to the date of death. From this the Commissioner has appealed.

The Commissioner objects to the decision on the ground that the “legacy which the decedent intended to give to her husband should not, by his action after her death, increase a deduction, which is intended to reflect the decedent’s gift to charity.”

The provision of the Revenue Act of 1926, c. 27, 44 Stat. 9, directly applicable to the taxation of Mrs. Macaulay’s estate read as follows:

“Sec. 303. For the purpose of the tax the value of the net estate shall be determined — ■

“(a) [as amended by section 403(a) of the Revenue Act of 1934, c. 277, 48 Stat. 680]. In the case of a citizen or resident of the United States, by deducting from the value of the gross estate—

*****

“(3) The amount of all bequests, legacies, devises, or transfers, to or for the use of the United States, any State, Terri *849 tory, any political subdivision thereof, or the District of Columbia, for exclusively public purposes, or to or for the use of any corporation organized and operated exclusively for religious, charitable, scientific, literary, or educational purposes. * * 26 U.S.C.A. Int.Rev.Acts, pages 232, 235.

In 1942 a further amendment to Section 303(a) (3) of the Act of 1926 was made which included in the amount of all charitable bequests, legacies, devises or transfers by a citizen or resident of the United States “the interest which falls into any such bequest, legacy, devise, or transfer as a result of an irrevocable disclaimer of a bequest, legacy, devise, transfer, or power, if the disclaimer is made prior to the date prescribed for the filing of the estate tax return.” Section 408(a) of the Revenue Act of 1942.

Section 408(c) of that Act provides: “The amendments made by this section shall be applicable to estates of decedents dying after February 10, 1939.” Mrs. Macaulay’s death in November, 1938, was before the date upon which the statutory amendment took effect. Counsel have argued at length whether the 1942 amendment was passed to clarify or declare existing law, or whether it was passed to change the existing law. The legislative history of the amendment seems to indicate that the Congressional intent was clarification rather than alteration. This appears from quotation from proceedings before the Congressional Committee set forth below. 1

It is evident from the proceedings in Congress that the amendment was intended to be applicable to two different *850 situations: First, to the case of a specific charitable bequest which a decedent by will had empowered another to divert to other purposes, and which under existing law was not allowable as a charitable deduction, and second, to the case of a disclaimed legacy which under the law of wills would fall into a residuary estate bequeathed to charity. In addition to this the amendment in either case set a definite limit (which had not before existed) in the case of the estates of decedents dying after February 10, 1939, to the time within which a disclaimer must be made to render a legacy deductible from the taxable estate.

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Bluebook (online)
150 F.2d 847, 34 A.F.T.R. (P-H) 106, 1945 U.S. App. LEXIS 4196, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commissioner-of-internal-rev-v-macaulays-estate-ca2-1945.