Pennsylvania Co. for Insurances on Lives & Granting Annuities v. Brown

70 F.2d 269, 13 A.F.T.R. (RIA) 960
CourtCourt of Appeals for the Third Circuit
DecidedMarch 20, 1934
DocketNo. 5255
StatusPublished
Cited by9 cases

This text of 70 F.2d 269 (Pennsylvania Co. for Insurances on Lives & Granting Annuities v. Brown) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pennsylvania Co. for Insurances on Lives & Granting Annuities v. Brown, 70 F.2d 269, 13 A.F.T.R. (RIA) 960 (3d Cir. 1934).

Opinion

PER CURIAM.

This is an appeal from a decree of the District Court disallowing a deduction of $327,-861.24 from the gross estate of Theodore C. Bimbaum claimed under section 303 (a) (3) of the Revenue Act of 1924 (26 USCA § 1095 note), which allows a deduction for all bequests made “to or for the use of any corporation organized and operated exclusively for religious, charitable, ¥ * * or educational purposes.”

The learned trial judge disallowed the deduction for the reason that the amount of the residuary bequests the charities designated in paragraph “Nineteenth, (i)” of the decedent’s will could not be determined at the time of his death with any reasonable certainty.

We are in entire accord with his conclusions, and affirm the decree for the reasons set forth in his opinion.

Affirmed.

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

Related

Polster v. Commissioner
31 T.C. 874 (U.S. Tax Court, 1959)
Graff v. Smith
100 F. Supp. 42 (E.D. Pennsylvania, 1951)
Commissioner of Internal Rev. v. Robertson's Estate
141 F.2d 855 (Fourth Circuit, 1944)
Baker-Boyer Nat. Bank v. Henricksen
46 F. Supp. 831 (W.D. Washington, 1942)
Gammons v. Hassett
121 F.2d 229 (First Circuit, 1941)
Hoagland v. Kavanagh
36 F. Supp. 875 (E.D. Michigan, 1941)
Ninth Bank & Trust Co. v. United States
15 F. Supp. 951 (E.D. Pennsylvania, 1936)

Cite This Page — Counsel Stack

Bluebook (online)
70 F.2d 269, 13 A.F.T.R. (RIA) 960, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pennsylvania-co-for-insurances-on-lives-granting-annuities-v-brown-ca3-1934.