Rodiek v. Commissioner
United States Board of Tax Appeals
1. As to decedent nonresidents, the part of the gross estate used in computing the net estate is confined to property situated in the United States.
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1. As to decedent nonresidents, the part of the gross estate used in computing the net estate is confined to property situated in the United States. Revenue Act of 1926, sec. 303(b). 2. The term "resident" as used for estate tax purposes means one whose domicil is in the United States. 3. In the case of an ordinary person who has a home, domicil relates with particularity to a place and not to a country or state in general. 4. A native German, who from 1877 to 1900 was in business in Hawaii and in 1900 became by collective naturalization a citizen of the United States, and soon thereafter,…
1Opinion of the Court
FREDRICK RODIEK, ANCILLARY EXECUTOR OF THE WILL OF JOHANN FRIEDRICH HACKFELD, DECEASED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Rodiek v. Commissioner
Docket No. 77997.
United States Board of Tax Appeals
33 B.T.A. 1020; 1936 BTA LEXIS 785;
February 11, 1936, Promulgated
1. As to decedent nonresidents, the part of the gross estate used in computing the net estate is confined to property situated in the United States. Revenue Act of 1926, sec. 303(b).
2. The term "resident" as used for estate tax purposes means one whose domicil is in the United States.
3. In the case of an…
2Cases cited33 opinions
- Poe v. SeabornSupreme Court of the United States · 1930
- Reinecke v. Northern Trust Co.Supreme Court of the United States · 1929
- Chase National Bank v. United StatesSupreme Court of the United States · 1929
- Tyler v. United StatesSupreme Court of the United States · 1930
- R. H. Stearns Co. v. United StatesSupreme Court of the United States · 1934
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