Estate of Crafts v. Commissioner

74 T.C. No. 105, 74 T.C. 1439, 1980 U.S. Tax Ct. LEXIS 50
CourtUnited States Tax Court
DecidedSeptember 25, 1980
DocketDocket No. 4443-79
StatusPublished
Cited by11 cases

This text of 74 T.C. No. 105 (Estate of Crafts v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Estate of Crafts v. Commissioner, 74 T.C. No. 105, 74 T.C. 1439, 1980 U.S. Tax Ct. LEXIS 50 (tax 1980).

Opinion

OPINION

Nims, Judge:

Respondent determined a deficiency in the Federal estate tax of the Estate of Nancy F. Crafts, deceased, William A. Dicus, personal representative (the estate), in the amount of $64,419.

Concessions having been made, the issues for decision are: (1) Whether a split-interest charitable remainder trust established by the will of decedent’s husband and includable in the estate by virtue of decedent’s general power of appointment is subject to the provisions of section 2055(e);1 (2) if section 2055(e) is applicable, whether a postmortem division of the trust property can qualify under section 2055(e)(3) or as a disclaimer under section 2055(a) so that the estate is entitled to a charitable deduction; and (3) whether the estate is entitled to an award for attorney’s fees and costs.

All of the facts in this case have been stipulated and are found accordingly. The stipulation and the attached exhibits are incorporated herein by reference.

At the time the petition in this case was filed, William A. Dicus resided in Dunedin, Fla. A timely estate tax return was filed on behalf of the estate on January 27, 1977.

Nancy F. Crafts, the decedent, died testate on October 29, 1975. The decedent had executed her will on June 15, 1973, with a first codicil executed October 15, 1975. The will, as amended by the codicil, was duly admitted to probate in the Circuit Court for Pinellas County, Fla., probate division.

Decedent was the widow of John Osborn Crafts (Mr. Crafts), who died testate on March 10, 1969.

Mr. Crafts’ will was executed on October 13, 1965, and was not republished by codicil or otherwise subsequent to that date. This will was duly admitted to probate in the County Judge’s Court, Pinellas County, Fla.

Mr. Crafts’ will created a testamentary trust of which decedent was named the life income beneficiary. The Toledo Trust Co. was named the sole trustee. In addition, the will vested in the decedent an inter vivos general power of appointment over the trust property, via an unrestricted power to invade trust corpus for decedent’s own benefit. The relevant provision of Mr. Crafts’ will on this point reads as follows: “My Trustee shall, from time to time, during the lifetime of my said wife, pay or distribute such part or all of the principal of said trust property to her as she may request in writing.” Mr. Crafts’ will provided for certain small gifts to be paid out of the trust corpus upon the decedent’s death. The residue remained in trust subject to the following conditions: Mr. Crafts’ brother, Osborn Crafts, was to receive $300 annually from trust income for the duration of his life;2 40 percent of the remaining trust income was to be paid to the Webb Institute of Naval Architecture (Webb Institute), with the 60-percent balance payable to certain noncharitable beneficiaries, all of whom were Mr. Crafts’ relatives; upon the death of the last to die of the individual income beneficiaries, 75 percent of the trust corpus was to be paid to the Webb Institute and 25 percent to Leicester Junior College.

Both the Webb Institute and Leicester Junior College are organizations described in section 2055(a) and were such organizations at the time of decedent’s death.

After the decedent’s death, the personal representative of her estate requested a determination from the Internal Revenue Service as to whether a charitable deduction was allowable for the value of the remainder interest passing to the charitable beneficiaries. By a letter ruling dated September 28, 1976, the Revenue Service determined that the estate was precluded from taking a charitable contribution deduction under section 2055(a) with respect to the remainder interest transferred to the Webb Institute and Leicester Junior College as the requirements of section 2055(e)(2) were not satisfied.

The personal representative subsequently requested a determination from respondent as to whether Mr. Crafts’ trust could be amended to comply with the requirements of section 2055(e). In a letter ruling dated November 26, 1976, respondent determined that the trust could not be amended under section 2055(e)(3). Respondent additionally ruled that the trust did not come within the savings clauses set forth in section 20.2055-2(e), Estate Tax Regs.

The provisions of the trust created by Mr. Crafts’ will gave the trustee broad discretionary powers to administer the trust property, including the power “to do all acts and things which it, in the exercise of its judgment and discretion, may deem needful, desirable and expedient for the proper and advantageous management of the trust property, to the same extent and with like effect as might be done in the exercise of ordinary prudence by an individual in absolute ownership and control of the property.” Among other things, Mr. Crafts’ will vested in the trustee the power “to make physical division of the trust property, and hold and administer each separate share for the benefit of the beneficiaries thereof.”

Pursuant to the above-mentioned powers, in January 1977, the trustee exercised its discretionary authority to effect a physical division of the trust property. As a consequence of the division, 40 percent of the trust property was set aside exclusively for the benefit of the Webb Institute, and the remaining 60 percent was set aside to provide life estates for the trust’s individual beneficiaries, with the remainder to the charities.

On the estate tax return, the full value of the trust property, $440,739.45, was included in decedent’s gross estate under “Schedule H-Powers of Appointment.” On “Schedule N-Charitable, Public and Similar Gifts and Bequests” the estate listed a $173,371.32 bequest to the Webb Institute. This figure was intended to represent the portion of the trust set aside exclusively for the Webb Institute and was arrived at by computing 40 percent of the net value of trust.

There is no dispute that the full value of the trust established by Mr. Crafts’ will is includable in the decedent’s gross estate under section 2041(a)(2) by reason of the general power of appointment over the trust principal vested in the decedent. Rather, the dispute here concerns the applicability of the constructive charitable bequest provisions of 2055(b)(1),3 and the extent, if any, to which section 2055(e) precludes the charitable deduction authorized under section 2055(a).

Bequests to or for the use of entities described in section 2055(a) are generally deductible from the gross estate. Pursuant to section 2055(b)(1), the interests in Mr. Crafts’ trust which passed to the Webb Institute and Leicester Junior College are, for purposes of section 2055, considered to be a bequest of the decedent. Nonetheless, it is evident that the bequests which were deemed to be made by the decedent constituted interests in a “split-interest” trust since both charitable and noncharitable beneficiaries had interests in the trust originally established by Mr. Crafts’ will. Thus it is apparent that, but for petitioner’s argument that section 2055(e)4 is inapplicable (discussed infra ), the interests passing to the Webb Institute and Leicester Junior College would be disallowed by the provisions of that section.

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74 T.C. No. 105, 74 T.C. 1439, 1980 U.S. Tax Ct. LEXIS 50, Counsel Stack Legal Research, https://law.counselstack.com/opinion/estate-of-crafts-v-commissioner-tax-1980.