Legal Opinion

Lockie v. Commissioner

United States Tax Court

Decided October 15, 1953No. Docket No. 32102Published

1. Estate Tax -- Gross Estate -- Dividend -- Section 811. -- A dividend declared prior to the death of the decedent but payable to stockholders of record on a date after his death is not includible in the gross estate. 2. Estate Tax -- Nonresident Alien -- Gross Estate -- Property Within the United States -- Section 861. -- Certificates connected with decedent's ownership of Bank of Nova Scotia stock and loans by the decedent to the British Treasury which were located in the…

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1. Estate Tax -- Gross Estate -- Dividend -- Section 811. -- A dividend declared prior to the death of the decedent but payable to stockholders of record on a date after his death is not includible in the gross estate. 2. Estate Tax -- Nonresident Alien -- Gross Estate -- Property Within the United States -- Section 861. -- Certificates connected with decedent's ownership of Bank of Nova Scotia stock and loans by the decedent to the British Treasury which were located in the United States at the time of decedent's death were not the property itself, the stock and the loans were not situated…

1Opinion of the Court

Estate of George McNaught Lockie, Deceased, Guaranty Trust Company of New York, Ancillary Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent

Lockie v. Commissioner

Docket No. 32102

United States Tax Court

21 T.C. 64; 1953 U.S. Tax Ct. LEXIS 49;

October 15, 1953, Promulgated

Decision will be entered under Rule 50.

1. Estate Tax -- Gross Estate -- Dividend -- Section 811. -- A dividend declared prior to the death of the decedent but payable to stockholders of record on a date after his death is not includible in the gross estate.

2. Estate Tax -- Nonresident Alien -- Gross Estate --…

Also in this document: Dissent.

2Cases cited1 opinion

  1. Lockie v. CommissionerUnited States Tax Court · 1953

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