Estate of Charania v. Comm'r
United States Tax Court
Decedent (D) and his wife were born and married in Uganda and were citizens of the United Kingdom. In 1972, they were exiled from Uganda and moved to Belgium. D and his wife did not formally change their marital regime under the procedures prescribed by the Belgian Civil Code. At the time of his death in 2002, 250,000 shares of Citigroup stock were held in D's name.
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Decedent (D) and his wife were born and married in Uganda and were citizens of the United Kingdom. In 1972, they were exiled from Uganda and moved to Belgium. D and his wife did not formally change their marital regime under the procedures prescribed by the Belgian Civil Code. At the time of his death in 2002, 250,000 shares of Citigroup stock were held in D's name. The estate contends that the shares were community property under Belgian law and that only one-half of the value of the shares is included in the value of the gross estate. The estate tax return was not timely filed. The estate…
1Opinion of the Court
OPINION
Cohen, Judge:
Respondent determined a deficiency in the Federal estate tax of the Estate of Noordin M. Charania (the estate) in the amount of $2,070,000.01 and an addition to tax under section 6651(a)(1) for the late filing of the estate tax return. The issues for decision are: (1) Whether the value of the gross estate includes the value of all of the shares of a U.S. corporation registered in the name of Noordin M. Charania (decedent), a nonresident alien, at his date of death and (2) whether the estate is liable for the section 6651(a)(1) addition to tax.
Unless otherwise indicated,…
2Cases cited9 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Commissioner of Internal Revenue v. Freeman P. Walker and Bernice WalkerCourt of Appeals for the Ninth Circuit · 1964
- Walker v. CommissionerUnited States Tax Court · 1962
- Zaffaroni v. CommissionerUnited States Tax Court · 1976
- Pittway Corporation and Subsidiaries v. United StatesCourt of Appeals for the Seventh Circuit · 1996
4 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- ESTATE OF CHARANIA v. ShulmanCourt of Appeals for the First Circuit · 2010
- Dynamo Holdings Limited Partnership, Dynamo, GP, Inc., Tax Matters Partner v. CommissionerUnited States Tax Court · 2018
- Estate of Charania v. Comm'rUnited States Tax Court · 2009
- Estate of Jensen v. Comm'rUnited States Tax Court · 2010
- Estate of Noordin M. Charania, Farhana Charania, Mehran Charania and Roshankhanu Dhanani, Administrators v. CommissionerUnited States Tax Court · 2009