Rev. Rul. 57-449

Where the decedent bequeathed the residue of his estate in trust, the income and principal of which was to be used to pay X dollars to all individuals who are enrolled as students in a particular school as of a particular date, the value of the trust is not deductible from the decedent's gross estate as a bequest for educational purposes under section 2055 of the Internal Revenue Code of 1954, unless the will as a whole may fairly be construed as creating a trust for educational purposes for the benefit of a general class, as distinguished from mere benevolence. Compare Estate of Harley J. Davis v. Commissioner , 26 T.C. 549, acquiescence page 8, this Bulletin, and Shenandoch Valley National Bank v. Taylor , 63 S.E.(2d) 786.