Article on Estate of Palumbo v. U.S.

Bridget J. Crawford (Pace University School of Law) recently published her note entitled Palumbo and the Estate Tax Charitable Deduction, 131 Tax Notes 423 (2011). The abstract available on SSRN is below:

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.