Worthington v. Commissioner
United States Tax Court
In determining the value of the decedent's interest in the estate of her grandfather for estate tax purposes, the respondent included in the gross estate evaluation certain cash on deposit and Federal Land Bank bonds held by the executor of the grandfather's estate as of the date of the decedent's death. The decedent was a nonresident alien not doing business in the United States at the time of her death.
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In determining the value of the decedent's interest in the estate of her grandfather for estate tax purposes, the respondent included in the gross estate evaluation certain cash on deposit and Federal Land Bank bonds held by the executor of the grandfather's estate as of the date of the decedent's death. The decedent was a nonresident alien not doing business in the United States at the time of her death. Held, the funds on deposit were cash on deposit by or for a nonresident alien not doing business in the United States at the time of her death and are therefore not includible in the gross…
1Opinion of the Court
OPINION.
Hill, Judge:
The petitioner did not include in the gross estate of Lesley Diana Worthington, a nonresident alien who was not engaged in business in the United States at the time of her death, certain cash in the amount of $80,522.36 on deposit with two New York banking firms in the account of Goodbody & Co. Goodbody & Co. was the agent of Marcus Goodbody, the executor of the estate of Lewis Nicholas Worthington, grandfather of the decedent.
The petitioner argues that the sum of $80,522.36 represented moneys deposited with the person carrying on the banking business by or for the…
2Cases cited6 opinions
- De Guebriant v. CommissionerUnited States Tax Court · 1950
- Jandorfs Estate v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1948
- Estate of Davey v. CommissionerUnited States Tax Court · 1948
- City Bank Farmers Trust Co. v. PedrickCourt of Appeals for the Second Circuit · 1948
- De Eissengarthen v. CommissionerUnited States Tax Court · 1948
1 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Oei Tjong Swan v. CommissionerUnited States Tax Court · 1955
- Resch v. CommissionerUnited States Tax Court · 1953
- Joachim v. CommissionerUnited States Tax Court · 1954
- Bank of New York v. United StatesDistrict Court, S.D. New York · 1957
- Estate of Ogarrio (Daguerre) v. CommissionerUnited States Tax Court · 1963
5 more not listed; retrieve them via the Exa API.