Transfers qualify for charitable deduction

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1. Burt made the following devises through his will:

(a) All of the preferred stock that he owned at the time of his death in X Corp. to a local nonprofit organization that operates as a shelter for homeless individuals (while leaving his common stock holdings to his grandchildren);

(b) A 50% interest as tenants in common in a downtown office building (subject to a lease by a commercial bank) to his city's nonprofit art museum;

(c) $100,000 to be distributed by his executor in her discretion to the § 2055(a) entity having the greatest positive influence on his community at the time of his death;

(d) $250,000 in trust, the terms of which require the trustee to pay Burt's daughter 5% of the value of the trust property on an annual basis for her lifetime, remainder to Burt's non-profit alma mater; and

(e) 6 months after Burt's death, his executor donates a perpetual easement on real property to the Nature Conservancy that requires the land to remain in its undeveloped natural state to protect native wildlife and to provide the public with access to an undeveloped beach front.

Determine whether the transfers qualify for the charitable deduction.

Reference no: EM133677433

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