Fifth Ave. Bank v. Commissioner
United States Board of Tax Appeals
Under the facts in this proceeding, the decedent is held to have been a resident of the United States at the date of death.
1Opinion of the Court
*537OPINION.
Harron:
The Commissioner contends that decedent was a nonresident of the United States, at the date of death, for estate tax purposes and that the provisions of section 303 (b), Revenue Act of 1926 are applicable in determining the net estate for tax purposes. The principal issue is whether decedent was a nonresident of the United States, with collateral issues relating to the taxable situs of a claim of the estate against one Marion Lozé, a resident of France, and to whether all or a proportion of administration expenses and fees is deductible from the gross estate.
The terms residence…
2Cases cited2 opinions
- Mitchell v. United StatesSupreme Court of the United States · 1875
- Williamson v. OsentonSupreme Court of the United States · 1914
3Cited by1 opinion
- Fifth Ave. Bank v. CommissionerUnited States Board of Tax Appeals · 1937