Jandorfs Estate v. Commissioner of Internal Revenue

SWAN, Circuit judge.

This appeal involves the federal estate tax of the estate of Karl Jandorf, a nonresident alien not engaged in business in the United States. At the date of his death on November 19, 1943, he was the beneficial owner of $150,000 of United States bonds physically located here, of which $75,000 were issued after March 1, 1941. The question for decision is whether the principal, plus accrued interest, of the bonds issued after March 1, 1941 was prop erly includible in the decedent’s gross estate. The Commissioner ruled that it was, producing the deficiency in suit, and the Tax…