St. Louis Union Trust Co. v. Commissioner
United States Board of Tax Appeals
1. Decedent, a native of this country living abroad, described himself as "of St. Louis, Missouri." Thereafter he took an oath of allegiance to Great Britain. He never returned to the United States to live, nor was he engaged in business here. After his death his administrators described him as being domiciled in this country at the time of death. Held, decedent was a nonresident alien when he died. 2. Decedent left property physically located in the United States.
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1. Decedent, a native of this country living abroad, described himself as "of St. Louis, Missouri." Thereafter he took an oath of allegiance to Great Britain. He never returned to the United States to live, nor was he engaged in business here. After his death his administrators described him as being domiciled in this country at the time of death. Held, decedent was a nonresident alien when he died. 2. Decedent left property physically located in the United States. It consisted of domestic corporation stocks and securities, United States bonds and certificates, corporate and municipal bonds,…
1Opinion of the Court
ST. LOUIS UNION TRUST COMPANY, EXECUTOR OF THE WILL OF WILLIAM NORTHRUP MCMILLAN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
St. Louis Union Trust Co. v. Commissioner
Docket No. 45966.
United States Board of Tax Appeals
27 B.T.A. 318; 1932 BTA LEXIS 1088;
December 14, 1932, Promulgated
1. Decedent, a native of this country living abroad, described himself as "of St. Louis, Missouri." Thereafter he took an oath of allegiance to Great Britain. He never returned to the United States to live, nor was he engaged in business here. After his death his administrators described him as…
2Cases cited10 opinions
- Crooks v. HarrelsonSupreme Court of the United States · 1930
- Baldwin v. MissouriSupreme Court of the United States · 1930
- Little v. BowersSupreme Court of the United States · 1890
- Scott v. CommissionerUnited States Board of Tax Appeals · 1931
- Brooks v. CommissionerUnited States Board of Tax Appeals · 1931
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