The Ninth Circuit Court of Appeals has affirmed a ruling that a decedent’s estate is not entitled to a charitable estate tax deduction for assets passed from the estate to a charitable trust. The Court held that the transfer was not accomplished by the decedent’s will. Prior to Howard Moore’s death, the Howard V. Moore Family Limited Partnership sold Moore Farms to a third party. Following Moore’s death, the Partnership transferred the proceeds of sale to a trust which had held a partnership interest for Moore’s benefit. The trust that had received the proceeds then transferred them to another trust and the Howard V. Moore Charitable Lead Trust. The IRS found that the proceeds from the sale...