The Tax Court has upheld an IRS ruling denying a charitable estate tax deduction for the value of the remainder interest of an attempted charitable remainder annuity trust when the stated annuity payment did not meet the statutory requirements for a CRAT. It has held that the trustees had no unilateral power to amend the instrument and had failed to obtain a necessary court reformation. Susan R. Block died in Connecticut in 2015, having left part of her estate in what she intended to be a CRAT for the benefit of her sister and her husband. She provided for a payment of an amount “equal to the greater of: (a) all net income, or (b) the sum of Fifty Thousand Dollars” at least annually. She...