Definition of Guaranteed Annuity and Lead Unitrust Interests

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This document amends the income, estate, and gift tax regulations to conform to the Tax Court's decision in Estate of Boeshore v. Commissioner. In Estate of Boeshore, the Tax Court held a certain provision of the Estate Tax Regulations invalid to the extent that it disallows a deduction for the value of a charitable unitrust interest if the charitable interest is preceded by a noncharitable interest that is in the form of a unitrust interest. This action is necessary to conform the income, estate, and gift tax regulations to the Tax Court's decision in Estate of Boeshore. The effect of these regulations is to allow an income, estate, or gift tax charitable deduction for charitable annuity or unitrust interests that are preceded by a noncharitable unitrust or annuity interest.