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Commissioner v. Estate of Sternberger, 348 U.S. 187 (1955)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Commissioner v. Estate of Sternberger, 348 U.S. 187 (1955)
Commissioner v. Estate of Sternberger No. 24 Argued October 19-20, 1954 Decided January 10, 1955 348 U.S. 187
CERTIORARI TO THE UNITED STATES COURT OF APPEALS
FOR THE SECOND CIRCUIT
Syllabus
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. 187-200.
(a) Section 81.44 of Treasury Regulations 105 does not authorize the deduction here claimed, and § 81.46 prohibits it. Pp. 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. 199.
207 F.2d 600, reversed.
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Chicago:
U.S. Supreme Court, "Syllabus," Commissioner v. Estate of Sternberger, 348 U.S. 187 (1955) in 348 U.S. 187 Original Sources, accessed July 1, 2025, http://www.originalsources.com/Document.aspx?DocID=2G4L8NFLRW9MKKB.
MLA:
U.S. Supreme Court. "Syllabus." Commissioner v. Estate of Sternberger, 348 U.S. 187 (1955), in 348 U.S. 187, Original Sources. 1 Jul. 2025. http://www.originalsources.com/Document.aspx?DocID=2G4L8NFLRW9MKKB.
Harvard:
U.S. Supreme Court, 'Syllabus' in Commissioner v. Estate of Sternberger, 348 U.S. 187 (1955). cited in 1955, 348 U.S. 187. Original Sources, retrieved 1 July 2025, from http://www.originalsources.com/Document.aspx?DocID=2G4L8NFLRW9MKKB.
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