Legal Opinion

Pulvermann v. Commissioner

United States Tax Court

Decided May 12, 1958No. Docket No. 63087Published

Held, bonds of a New Jersey corporation, which were owned by a nonresident alien at the time of their destruction in England, were not situated in the United States within the meaning of section 861 (a), I. R. C. 1939, at the time of the alien's death abroad some 3 years later.

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Held, bonds of a New Jersey corporation, which were owned by a nonresident alien at the time of their destruction in England, were not situated in the United States within the meaning of section 861 (a), I. R. C. 1939, at the time of the alien's death abroad some 3 years later. Held, further, under the facts, the bonds were not physically situated in the United States at the time decedent made a revocable transfer of the bonds to his son, within the provisions of section 862 (b), I. R. C. 1939.

1Opinion of the Court

Curt E. Pulvermann, a Beneficiary of the Estate of Eduard F. Pulvermann, Deceased, Petitioner, v. Commissioner of Internal Revenue, Respondent

Pulvermann v. Commissioner

Docket No. 63087

United States Tax Court

30 T.C. 231; 1958 U.S. Tax Ct. LEXIS 197;

May 12, 1958, Filed

Decision will be entered for the petitioner.

Held, bonds of a New Jersey corporation, which were owned by a nonresident alien at the time of their destruction in England, were not situated in the United States within the meaning of section 861 (a), I. R. C. 1939, at the time of the alien's death abroad some 3 years later. Held,…

Also in this document: Dissent.

2Cases cited5 opinions

  1. Burnet v. BrooksSupreme Court of the United States · 1933
  2. New York Ex Rel. New York Central & Hudson River Railroad v. MillerSupreme Court of the United States · 1906
  3. Delaney v. MurchieCourt of Appeals for the First Circuit · 1949
  4. Nicholson v. NicholsonMontana Supreme Court · 1923
  5. Pulvermann v. CommissionerUnited States Tax Court · 1958

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