This section contains the nature of the case and procedural background.

The testatrix's will left all her residuary estate to such charitable and benevolent, religious or educational institutions as her executors hereinafter named may determine. The IRS disallowed all such legacy deductions upon the theory that Ps has power to appoint said remainder and residue exclusively to benevolent institutions that were not also charitable.

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Legal analysis from Dean's Law Dictionary will be displayed here.