The dedication of property for the saying of Masses or Kaddish atYahrzeit is a charitable use. The funds directed to be employed for these purposes aid the advancement of the Roman Catholic and Jewish religions to the same extent as other gifts to religious organizations of these faiths. In addition, the religious doctrines of these faiths declare that the religious services benefit the entire community and not merely the decedent remembered in the service. Probably, however, it would be best for courts to avoid the theological thicket in deciding whether or not a dedication of property for religious services is a charitable use.
James T. Brennan, Bequests for Religious Services, 17 Clev.-Marshall L. Rev. 388 (1968)