Garvan v. Commissioner
United States Board of Tax Appeals
1. Where paper evidences of shares of stock of a foreign corporation and bonds of foreign governments belonging to a nonresident alien were held within the United States for certain restricted purposes, such stock and bonds may not be included for purposes of taxation in the estate of such nonresident alien, because they were not property situated within the United States within the meaning of the statute.
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1. Where paper evidences of shares of stock of a foreign corporation and bonds of foreign governments belonging to a nonresident alien were held within the United States for certain restricted purposes, such stock and bonds may not be included for purposes of taxation in the estate of such nonresident alien, because they were not property situated within the United States within the meaning of the statute. Ernest Brooks et al.,22 B.T.A. 71, followed. 2. Shares of stock of domestic corporations, similarly owned and held, may be included in decedent's estate by authority of section 303(d) of…
1Opinion of the Court
*613OPINION.
Goodeich:
This proceeding is for the redetermination of a deficiency in estate tax of $9,661.04. Petitioner also challenges the validity of the original assessment of estate tax in the amount of $71,914.58, which it has heretofore paid under protest.
The following stipulation was filed:(1) It Is hereby stipulated by and between the parties in the above-entitled action that the following facts are admitted and need not be proved.(2) The petitioner is the First National Bank of Boston as Administrator of the Estate of Sir John Joseph Garvan. The legal residence of the decedent, Sir John…
2Cases cited15 opinions
- Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
- Brushaber v. Union Pacific RailroadSupreme Court of the United States · 1916
- Nichols v. CoolidgeSupreme Court of the United States · 1927
- Blodgett v. HoldenSupreme Court of the United States · 1927
- McCray v. United StatesSupreme Court of the United States · 1904
10 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Igleheart v. CommissionerUnited States Board of Tax Appeals · 1933
- Travelers Bank & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Crocker v. CommissionerUnited States Board of Tax Appeals · 1933
- Crocker v. CommissionerUnited States Board of Tax Appeals · 1933
- Garvan v. CommissionerUnited States Board of Tax Appeals · 1932
2 more not listed; retrieve them via the Exa API.