Legal Opinion

Fairchild v. Commissioner

United States Tax Court

Decided June 16, 1955No. Docket No. 47730Published

Estate Tax -- Citizen of the United States -- Domiciled in Virgin Islands -- Sec. 802, I. R. C. (1939). -- The decedent, a lifetime citizen of the United States, domiciled for over 12 years and at the time of his death in the Virgin Islands, held not a citizen of the United States within the meaning of section 802, 1939 Code, for Federal estate tax purposes.

1Opinion of the Court

Estate of Arthur S. Fairchild, Deceased, Homer D. Wheaton and Bank of New York (formerly Bank of New York and Fifth Avenue Bank), Executors, Petitioner, v. Commissioner of Internal Revenue, Respondent

Fairchild v. Commissioner

Docket No. 47730

United States Tax Court

24 T.C. 408; 1955 U.S. Tax Ct. LEXIS 169; 3 V.I. 465;

June 16, 1955, Filed

Deciison will be entered under Rule 50.

Estate Tax -- Citizen of the United States -- Domiciled in Virgin Islands -- Sec. 802, I. R. C. (1939). -- The decedent, a lifetime citizen of the United States, domiciled for over 12 years and at the time of his death in…

2Cases cited3 opinions

  1. Smallwood v. CommissionerUnited States Tax Court · 1948
  2. Commissioner of Internal Revenue v. Rivera's EstateCourt of Appeals for the Second Circuit · 1954
  3. Fairchild v. CommissionerUnited States Tax Court · 1955

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