Cromwell v. Commissioner
United States Board of Tax Appeals
1. Value of personalty located abroad held properly included in gross estate of a resident decedent. Guaranty Trust Co., Executor,21 B.T.A. 330, followed. 2. Inclusion in decedent's gross estate of value of property transferred within two years prior to death, the transfer not being admitted or shown in fact to have been made in contemplation of or intended to take effect at or after death, held to be erroneous, following Estate of Robert Todd Lincoln,24 B.T.A. 334. 3.…
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1. Value of personalty located abroad held properly included in gross estate of a resident decedent. Guaranty Trust Co., Executor,21 B.T.A. 330, followed. 2. Inclusion in decedent's gross estate of value of property transferred within two years prior to death, the transfer not being admitted or shown in fact to have been made in contemplation of or intended to take effect at or after death, held to be erroneous, following Estate of Robert Todd Lincoln,24 B.T.A. 334. 3. Respondent's method of valuing bequest to educational institution sustained.
1Opinion of the Court
*462OPINION.
Aetondell :
We have set out as our findings of fact only the facts that relate to the issues left for decision. Other stipulations of fact and waivers of issues will be mentioned briefly here.
Petitioners waived an issue relating to the inclusion in the estate of certain cash securities and cash held by Bankers Trust Company as trustee for Gustave Frederick Dutschke and consented to the inclusion thereof at the value of $164,813.49 as fixed by respondent.
The parties agree that the amount of the residuary estate passing to Harvard University, which is stipulated to be an educational…
2Cases cited1 opinion
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
3Cited by8 opinions
- Luehrmann v. CommissionerUnited States Tax Court · 1959
- Hartford Nat. Bank & Trust Co. v. United StatesDistrict Court, D. Connecticut · 1952
- Cromwell v. CommissionerUnited States Board of Tax Appeals · 1931
- Estate of Gertrude Dodd v. CommissionerUnited States Tax Court · 1947
- Foster v. CommissionerUnited States Board of Tax Appeals · 1932
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