Legal Opinion

Cromwell v. Commissioner

United States Board of Tax Appeals

Decided October 26, 1931No. Docket No. 42619Published

1. Value of personalty located abroad held properly included in gross estate of a resident decedent. Guaranty Trust Co., Executor,21 B.T.A. 330, followed. 2. Inclusion in decedent's gross estate of value of property transferred within two years prior to death, the transfer not being admitted or shown in fact to have been made in contemplation of or intended to take effect at or after death, held to be erroneous, following Estate of Robert Todd Lincoln,24 B.T.A. 334. 3.…

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1. Value of personalty located abroad held properly included in gross estate of a resident decedent. Guaranty Trust Co., Executor,21 B.T.A. 330, followed. 2. Inclusion in decedent's gross estate of value of property transferred within two years prior to death, the transfer not being admitted or shown in fact to have been made in contemplation of or intended to take effect at or after death, held to be erroneous, following Estate of Robert Todd Lincoln,24 B.T.A. 334. 3. Respondent's method of valuing bequest to educational institution sustained.

1Opinion of the Court

WILLIAM NELSON CROMWELL, AND JOHN FOSTER DULLES, SURVIVING EXECUTORS OF THE ESTATE OF AUGUSTUS COE GURNEE, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Cromwell v. Commissioner

Docket No. 42619.

United States Board of Tax Appeals

24 B.T.A. 461; 1931 BTA LEXIS 1637;

October 26, 1931, Promulgated

1. Value of personalty located abroad held properly included in gross estate of a resident decedent. Guaranty Trust Co., Executor,21 B.T.A. 330, followed.

2. Inclusion in decedent's gross estate of value of property transferred within two years prior to death, the transfer not being admitted…

2Cases cited4 opinions

  1. Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
  2. American Sec. & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1931
  3. Cromwell v. CommissionerUnited States Board of Tax Appeals · 1931
  4. Guaranty Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1930

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