De Perigny v. Commissioner
United States Tax Court
Value of 99-year leasehold interests (exchangeable for 999-year interests) in land situated in Kenya Colony, British East Africa, held excludible from decedent's gross estate for Federal estate tax purposes, as "real property situated outside of the United States," under Internal Revenue Code, sec. 811.
1Opinion of the Court
Estate of Margaret Thaw Carnegie de Perigny, Fidelity Trust Company, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent
De Perigny v. Commissioner
Docket No. 6679
United States Tax Court
9 T.C. 782; 1947 U.S. Tax Ct. LEXIS 52;
October 28, 1947, Promulgated
Decision will be entered under Rule 50.
Value of 99-year leasehold interests (exchangeable for 999-year interests) in land situated in Kenya Colony, British East Africa, held excludible from decedent's gross estate for Federal estate tax purposes, as "real property situated outside of the United States," under Internal Revenue…
2Cases cited9 opinions
- Helvering v. HallockSupreme Court of the United States · 1940
- J. W. Perry Co. v. City of NorfolkSupreme Court of the United States · 1911
- Wells v. Mayor of SavannahSupreme Court of Georgia · 1891
- Wells v. SavannahSupreme Court of the United States · 1901
- Ralston Steel Car Co. v. RalstonOhio Supreme Court · 1925
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