Commissioner v. Estate of SternbergerAnnotate this Case
348 U.S. 187 (1955)
U.S. Supreme Court
Commissioner v. Estate of Sternberger, 348 U.S. 187 (1955)
Commissioner v. Estate of Sternberger
Argued October 19-20, 1954
Decided January 10, 1955
348 U.S. 187
In determining a net estate for federal estate tax purposes, a deduction may not be made under § 812(d) of the Internal Revenue Code on account of a charitable bequest that is to take effect only if decedent's childless 27-year-old daughter dies without descendants surviving her and her mother. Humes v. United States,276 U. S. 487. Pp. 348 U. S. 187-200.
(a) Section 81.44 of Treasury Regulations 105 does not authorize the deduction here claimed, and § 81.46 prohibits it. Pp. 348 U. S. 190-199.
(b) There is no statutory authority for the deduction from a gross estate of any percentage of a conditional bequest to charity where there is no assurance that charity will receive the bequest or some determinable part of it. P. 348 U. S. 199.
207 F.2d 600, reversed.
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