Estate of Lawler v. Commissioner

52 T.C. 268, 1969 U.S. Tax Ct. LEXIS 131
CourtUnited States Tax Court
DecidedMay 15, 1969
DocketDocket No. 4584-66
StatusPublished
Cited by5 cases

This text of 52 T.C. 268 (Estate of Lawler 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 Lawler v. Commissioner, 52 T.C. 268, 1969 U.S. Tax Ct. LEXIS 131 (tax 1969).

Opinion

OPINION

Respondent disallowed a part of the charitable deduction claimed by petitioner, as executor of the Estate of Florence H. Lawler, on decedent’s Federal estate tax return. It is respondent’s contention that the gift of “Fund C” under the terms of the Florence H. Lawler Trust, which trust was included in decedent’s gross estate, is invalid under Virginia law and, therefore, the Estate of Florence H. Lawler is not entitled to a charitable deduction for the value of “Fund C” in computing its Federal estate tax. Respondent agrees that if the gift is valid under the law of Virginia it is a proper deduction from decedent’s adjusted gross estate.

Our decision on this issue rests largely on the law of Virginia; we therefore deem it advisable to touch briefly on the foundations of Virginia jurisprudence regarding charitable bequests.

In Baptist Association v. Hart's Executors, 4 Wheat. 1 (1819), the Supreme Court, speaking through Chief Justice Marshall, held that the charitable bequest of a Virginia testator could not be established by a court'of equity, independent of the statute of 43 Eliz., ch, 4 (often referred to as the Statute of Charitable Uses), and since the statute of 43 Elizabeth was repealed in 1792 by Virginia’s general repeal of Eng-list Statutes, the bequest was void. Twenty-five years later tbe Supreme Court, in Vidal et al. v. Girard's Executors, 2 How. 126 (1844), distinguished the Hart decision and noted that the English Court of Chancery entertained jurisdiction over charities long before the statute of 48 Elizabeth.3

In the interim, between the Hart and Vidal decisions, the Supreme Court of Appeals of Virginia decided Gallego's ex'ors v. Attorney General, 3 Leigh 450, 30 Va. 487 (1832). In Gallego it was held that a trust for indefinite beneficiaries was invalid and that indefinite bequests for charitable purposes could only be sustained under the statute of 43 Elizabeth, which was repealed by the State of Virginia in 1792.

Although Gallego was decided before Vidal, the Gallego court did not rely entirely on the opinion of Chief Justice Marshall in Hart. Speaking for the court in Gallego, Judge Tucker stated (30 Va. at 516-517):

a just respect to the policy of the legislature, in relation to religious charities especially; a prudent caution on our part, in assuming doubtful powers; a due sense of the infinite difficulty and embarrassment, which must attend the search after the common law doctrines anteriour to the statute of Elizabeth; and a just view of the danger of reviving these obsolete doctrines; — must determine us to leave the subject to the wisdom of the legislature itself. * * *

As an aftermath to Judge Tucker’s opinion in Gallego, the Virginia legislature in 1839 and in 1841 promulgated statutes validating charitable (literary and educational) and religious gifts respectively. These statutes were the predecessors of what is presently section 55-26 and section 57-7 of the Virginia Code of 1950. The legislature, however, fearful that an accumulation of wealth by religious institutions would result in an intermeddling in the affairs of government, permitted only transfers of realty and restricted the quantity of said transfers. Beginning in 1902, and by subsequent amendments, the Virginia legislature authorized gifts of specific amounts of personalty to religious institutions (presently sec. 57-12). See Maguire v. Loyd, 193 Va. 138, 67 S.E. 2d 885 (1951).

Although the Supreme Court’s opinion in Hart, was subsequently reexamined in Vidal and found to be erroneous, the Virginia Court of Appeals’ decision in Gallego, that a trust for indefinite beneficiaries could only be validated by an act of the legislature, remains today as a viable doctrine of Virginia jurisprudence. See Moore v. Perkins, 169 Va. 175, 177, 192 S.E. 806, 807 (1937); Maguire v. Loyd, supra; and see Smith v. Moore, 343 F. 2d 594, 599-600 (C.A. 4, 1965).

In line with Virginia’s fear of organized religions intermeddling in the affairs of government, the present constitution of Virginia provides in article IV, section 59, that “The General Assembly shall not grant a charter of incorporation to any church or religious denomination, but may secure the title to church property to an extent to be limited by law.” Although this provision first appeared4 in the constitution of 1850, and was subsequently included in each succeeding constitution,5 its germination may be traced to the Revolution and the Bill of Rights wherein the church and state were disestablished. Thus, the purpose of this constitutional provision was to reaffirm the separation of church and state and not to prevent the holding of property by organized religion. Trustees Gen. Assem. Presbyterian Church U.S. v. Guthrie, 86 Va. 125, 10 S.E. 318, 322 (1889). Accordingly, the incorporation of church agencies essential to the accomplishment of church work has been held not to be the incorporation of a church and, therefore, a bequest to such an organization is not rendered invalid. Trustees Gen. Assem. Presbyterian Church U.S. v. Guthrie, supra. Thus, in Virginia today, title to church property may be secured to an extent limited by law, however, both charitable and religious trusts for the benefit of indefinite beneficiaries must be validated by an act of the legislature.

Accordingly, under the law of Virginia, charitable bequests, exclusive of transfers to religious organizations, are validated by section 55-26 of the Virginia Code of 1950 (hereinafter referred to as section 55-26). Transfers to lay trustees for religious organizations are validated by section 57-7 of the Virginia Code of 1950 (hereinafter referred to as section 57-7) and limitations upon the quantity of realty and personalty that said trustees may hold under section 57-7 are imposed by section 57-12 of the Virginia Code of 1950 (hereinafter referred to as section 57-12). Provision is also made under section 57-16 of the Virginia Code of 1950 (hereinafter referred to as section 57-16) for the acquisition of property by an appointed bishop, minister, or other ecclesiastical officer whenever the laws, rules, or ecclesiastical polity of any church commits to said bishop, minister, or ecclesiastical officer authority to administer its aifairs. This section was enacted in 1942.

Petitioner contends that Fund C of the trust constitutes a valid charitable bequest under section 55-26.6 To support his contention, petitioner argues that the main purpose of Fund 0 is “missionary purposes of the Diocese of Richmond” and, therefore by definition, is not a gift to a religious institution which would be governed by section 57-7.

Petitioner’s attempt to categorize Fund C as a charitable bequest under section 55-26 through the use of the word “missionary” must fail. The whole tenor of Fund C indicates that the bequest was not intended to be totally nonsecular. To accept petitioner’s argument, therefore, would be to circumvent the intent of the Virginia legislature as expressed in sections 57-7, 57-12, and 57-16. Moreover, we find support for this analysis in Moore v. Perkins, supra, where the Supreme Court of Appeals of Virginia held that a bequest of money to be administered by a named pastor, who was to pay the interest earned on said money “to the Methodist Church South for missionary work where he thinks it will do the greatest good,” did not fall within section 55-26.

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Related

Estate of McAllister v. Commissioner
54 T.C. 1407 (U.S. Tax Court, 1970)
Estate of McGillicuddy v. Commissioner
54 T.C. 315 (U.S. Tax Court, 1970)
Estate of Lawler v. Commissioner
52 T.C. 268 (U.S. Tax Court, 1969)

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Bluebook (online)
52 T.C. 268, 1969 U.S. Tax Ct. LEXIS 131, Counsel Stack Legal Research, https://law.counselstack.com/opinion/estate-of-lawler-v-commissioner-tax-1969.