5 Pages Posted: 26 Apr 2011
Date Written: April 25, 2011
This Estate and Gift Tax Rap column for Tax Notes is an extended discussion of the United States District Court (W.D. Pa.) decision in Estate of Palumbo v. U.S.. In that case, the court upheld a claimed estate tax charitable deduction for amounts passing to charity pursuant to a settlement of a will contest. The court cited legislative history, case law precedent respecting arm’s-length settlements as the equivalent of will transfers, and the strength of the the charitable legatee’s claim against the estate.
Keywords: will, estate, estate tax, charity, charitable deduction, will contest, settlement, deduction, Palumbo
JEL Classification: K34
Suggested Citation: Suggested Citation
Crawford, Bridget J., Palumbo and the Estate Tax Charitable Deduction (April 25, 2011). Tax Notes, Vol. 131, p. 423, 2011. Available at SSRN: https://ssrn.com/abstract=1807427