Joachim v. Commissioner
United States Tax Court
Funds representing nonresident alien decedent's remainder interest in a trust were, pursuant to a decree of the Surrogate's Court, paid to the Treasurer of the City of New York for her benefit. He deposited them in a bank in his name. Thereafter, but before decedent's death, the Alien Property Custodian issued a vesting order.
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Funds representing nonresident alien decedent's remainder interest in a trust were, pursuant to a decree of the Surrogate's Court, paid to the Treasurer of the City of New York for her benefit. He deposited them in a bank in his name. Thereafter, but before decedent's death, the Alien Property Custodian issued a vesting order. After her death in May 1943, the decree of the Surrogate's Court was amended to authorize withdrawal of funds by the Custodian who received them in March 1944. Held, disregarding for tax purposes the vesting of title to the deposited funds by the Custodian, as required…
1Opinion of the Court
Estate of Lina Joachim, Deceased, Richard H. Joachim, Beneficiary, Petitioner, v. Commissioner of Internal Revenue, Respondent
Joachim v. Commissioner
Docket No. 41637
United States Tax Court
22 T.C. 875; 1954 U.S. Tax Ct. LEXIS 142;
July 14, 1954, Filed July 14, 1954, Filed
Decision will be entered for the petitioner.
Funds representing nonresident alien decedent's remainder interest in a trust were, pursuant to a decree of the Surrogate's Court, paid to the Treasurer of the City of New York for her benefit. He deposited them in a bank in his name. Thereafter, but before decedent's death, the Alien…
2Cases cited8 opinions
- Cummings v. Deutsche Bank Und DiscontogesellschaftSupreme Court of the United States · 1937
- De Guebriant v. CommissionerUnited States Tax Court · 1950
- Weiss v. CommissionerUnited States Tax Court · 1946
- Estate of Davey v. CommissionerUnited States Tax Court · 1948
- City Bank Farmers Trust Co. v. PedrickCourt of Appeals for the Second Circuit · 1948
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