Legal Opinion
City Bank Farmers Trust Co. v. Pedrick
District Court, S.D. New York
Decided January 3, 1947No. Civ. No. 32-415PublishedCited by 2 opinions
1Opinion of the Court
BYERS, District Judge.
The question for decision is whether Section 863(b) of the Internal Revenue Code, 26 U.S.C.A. Int.Rev.Code, § 863(b), applies to the bank account hereinafter described so that it is not to be deemed property within the United States, for estate taxation.
The statute reads:
“ § 863. Property without the United States
“The following items shall not, for the purpose of this subchapter (Basic Estate Tax), be deemed property within the United States:
“ (a) * * * (Not involved).
“(b) Bank deposits. Any moneys deposited with any person carrying on the banking business, by or for a…
2Cases cited3 opinions
- In re the Trust Estate Created by & under the Provisions of the Last Will & Testament of HowellAppellate Division of the Supreme Court of the State of New York · 1932
- Fesenmeyer v. Salt Springs Nat. BankCourt of Appeals for the Second Circuit · 1937
- In re Arcadia Trust Co.Appellate Division of the Supreme Court of the State of New York · 1934
3Cited by2 opinions
- Estate of Oei Tjong Swan, Oei Ing Tjhing v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- City Bank Farmers Trust Company v. United StatesDistrict Court, S.D. New York · 1959