Estate of McAllister v. Commissioner

54 T.C. 1407, 1970 U.S. Tax Ct. LEXIS 103
CourtUnited States Tax Court
DecidedJune 25, 1970
DocketDocket No. 5444-67
StatusPublished
Cited by4 cases

This text of 54 T.C. 1407 (Estate of McAllister 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 McAllister v. Commissioner, 54 T.C. 1407, 1970 U.S. Tax Ct. LEXIS 103 (tax 1970).

Opinion

OPINION

Section 2106(a)(2) provides a deduction from the gross estate, situated in the United States at the time of death, of a nonresident alien if the following conditions are met:

SEC. 2106. TAXABLE ESTATE.
(2) TRANsmses jtoe Public, Charitable, and Religious Uses.—
(A) In General. — The amount of all bequests, legacies, devises, or transfers * * *
# * * * * * *
(iii) to a trustee or trustees, * * *, but only if such contributions or gifts are to be used within the United States by such trustee or trustees * * * exclusively for religious, charitable, scientific, literary, or educational purposes, * * ⅜

In the case at bar it is the respondent’s contention that the decedent’s devise, of 25 percent of his residuary estate to a Canadian foundation for the benefit of engineering students who attend Michigan (sometimes hereinafter referred to as the Michigan ¡bequest), fails to meet section 2106(a) (2) on two grounds. First, the Michigan bequest was dependent upon the performance of a precedent event and the possibility that the bequest would not become effective was not “so remote as to be negligible.” Sec. 20.2106-1 (a) (2), Estate Tax Regs.; sec. 20.2055-2 (b), Estate Tax Regs. Second, assuming the possibility that the bequest would not become effective was so remote as to be negligible, it, nonetheless, fails to meet the terms of section 2106(a) (2) (A) (iii) because the bequest was not to trustees for use within the United States. We will consider the respondent’s contentions each in turn.

The decedent’s will provides, in pertinent part:

If and wlien the Michigan College of Mining and Technology, Houghton, Michigan, U.S.A., establishes in Canada to the satisfaction of my Trustees, a charitable foundation corporation or ia charitable truát so that monies may be received by it in Canada from my estate and others and the said money spent in Canada without income tax or succession duty levies of any kind, then on that happening, and only then, my Trustees are to pay the remaining twenty-five percent of the net annual income to the said charitable foundation ⅜ ⅞ *

It is the respondent’s position that the above-quoted dispositive paragraph contains three conditions which according to the terms of the decedent’s will had to be satisfied before the Michigan bequest could become effective:

1. That Michigan establish a foundation in Canada;

2. that the foundation qualify for Canadian tax exemption; and

3. that the trustees of the decedent’s estate be satisfied with the foundation as completed.

We hold that despite these conditions, considered individually and in toto, the possibility that the Michigan bequest would not become effective was so remote as to be negligible.

The question of remoteness is purely factual. Estate of Russell Harrison Varian, 47 T.C. 34, 48 (1966), affd. 396 F. 2d 753 (C.A. 9, 1968); Estate of Abraham L. Buchwalter, 46 T.C. 805, 818 (1966). As noted, our careful consideration of all of the facts and circumstances convinces us that there was a mere negligible possibility that the bequest would fail. Estate of Bussell Harrison Varían, supra at 50.

As to the first condition, one can safely presume that Michigan would take all steps necessary to avail itself of the benefits of the $325,-159.58 bequest. This is particularly true since, as we have indicated in our findings of fact, all that was required of Michigan was that it request the decedent’s executors to proceed.

On brief respondent makes mention of the fact that the decedent’s will directed that financial assistance be extended to “plodders” who otherwise might not be able to attend Michigan. It is the respondent’s contention that Michigan might not find these “plodders” desirable as students. We do not feel that this fact would tend to influence Michigan’s decision against acceptance of the bequest. The decedent’s will provided that assistance be rendered “worthwhile students.” And we believe that it is generally recognized that not all worthwhile students are possessed of mercurial intelligence. A plodder is “a person who proceeds or works slowly, steadily, and unimaginatively.” Webster’s Third New International Dictionary (1969 unabridged). While not scholarship material in one sense it is our view that these slow but diligent students would be a welcome addition to the college campuses of the day.

Respondent's other arguments on this point are concerned with whether the bequest would be of financial benefit to Michigan rather than merely creating additional burdens by reason of an influx of students. However, it is the function of a college to benefit students and while it may be argued that colleges would be less burdened with fewer students we find this method of reasoning sophistic.

As to the matter of obtaining Canadian tax exemptions, we find the possibility of failure so remote as to be negligible. As it appears from our findings of fact securing rulings from appropriate authorities was merely a matter of proceeding through administrative channels. The Canadian taxing authorities were charged with interpreting existing law in much the same fashion that our Internal Revenue Service is so charged. Since the petitioners ultimately obtained the exemption's and since the determinations of the Canadian taxing authorities relate back to the date of decedent’s death, it seems that there were never any obstacles to the requisite exemptions. It was almost a certainty from the outset that this condition of the Michigan bequest would be satisfied. The relative ease with which the exemptions were procured certainly supports this conclusion.

The respondent contends that there was a “strong possibility” that the exemptions would not be forthcoming because section 62(1) (f) of the Income Tax Act of the Dominion of Canada requires that funds be used in Canada before exemption is permitted. Without delving into the mysteries of Canadian tax law it suffices to say that we are blessed with the opinions of Canada’s Department of National Revenue, Taxation Division, and Ontario’s Treasury Department, Succession Duty Office, which, in fact, granted exemption.3

As to the third condition, i.e., the satisfaction of the decedent’s trustees, we also hold that the possibility of failure was so remote as to be negligible. Once the foundation had been established and the tax exemption assured the trustees were powerless to withhold approval. Under the terms of the decedent’s will the trustees were merely given the duty of seeing to it that a tax-exempt foundation was established. The respondent contends that the trustees were given no standards and that their discretion was unbounded. However, the intention of the decedent is manifest from the face of his will and the discretion of the trustees was clearly circumscribed by this manifestation.

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Related

Estate of Silver v. Comm'r
120 T.C. No. 14 (U.S. Tax Court, 2003)
Estate of McAllister v. Commissioner
54 T.C. 1407 (U.S. Tax Court, 1970)

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Bluebook (online)
54 T.C. 1407, 1970 U.S. Tax Ct. LEXIS 103, Counsel Stack Legal Research, https://law.counselstack.com/opinion/estate-of-mcallister-v-commissioner-tax-1970.