Siegel v. United States

LITTLETON, Judge.

The principal question in this case is whether this suit was barred at the time it was instituted. We are of opinion that *773it was not. Section 403 (b) (2) and (3) of the Revenue Act of 1921 provided, so far as pertinent here, as follows:

“In the case of a nonresident, by deducting from the value of that part of his gross estate which at the time of his death is situated in the United States * * * an amount equal to the value of any property forming a part of the gross estate situated in the United States of any person who died within five years prior to the death of the…