Forni v. Commissioner
United States Board of Tax Appeals
A fund of $41,020.48 credited to decedent in the customer's ledger account of a trust company held to constitute "moneys deposited" within the meaning of section 303(e) of the Revenue Act of 1926, as amended by section 403(d) of the Revenue Act of 1934.
1Opinion of the Court
OPINION.
Van Fossan:
The respondent determined a deficiency of $8,459.70 in the estate tax of the estate of Annina Fabbricotti Fara Forni. The petitioner claims an overpayment of $9,434.71.
The petition raised several issues, all of which have been settled except the question whether or not a fund of $41,020.48, held by the United States Trust Co., constituted “moneys deposited” within the meaning of that phrase as found in section 303 (e) of the Revenue Act of 1926, as amended by section 403 (d) of the Revenue Act of 1934.
*77The facts were stipulated and as so stipulated we adopt them as our…
2Cases cited2 opinions
- Marine Bank v. Fulton BankSupreme Court of the United States · 1865
- Gimbel Bros. v. WhiteAppellate Division of the Supreme Court of the State of New York · 1939
3Cited by3 opinions
- Estate of Ogarrio (Daguerre) v. CommissionerUnited States Tax Court · 1963
- Estate of Ogarrio (Daguerre) v. CommissionerUnited States Tax Court · 1963
- Forni v. CommissionerUnited States Board of Tax Appeals · 1942