Zietz v. Commissioner
United States Tax Court
The parents of the petitioner, Willy Zietz, were citizens of Germany. Hugo Zietz, the father, died testate in Germany in 1927. German law governs the construction of his will. Hugo in his will appointed his widow, Hedwig, the provisional heir of his estate for life and his sons the final or reversionary heirs to succeed their mother.
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The parents of the petitioner, Willy Zietz, were citizens of Germany. Hugo Zietz, the father, died testate in Germany in 1927. German law governs the construction of his will. Hugo in his will appointed his widow, Hedwig, the provisional heir of his estate for life and his sons the final or reversionary heirs to succeed their mother. Hedwig died intestate, a resident of Switzerland, in 1945. Willy Zietz was the sole survivor, his brother, Hugo, Jr., having died in 1934. Although under the will, Hedwig had the power to invade the principal of the estate for the use of herself and sons, such…
1Opinion of the Court
Willy Zietz and Elisabeth D. Zietz, Petitioners, v. Commissioner of Internal Revenue, Respondent
Zietz v. Commissioner
Docket No. 49427
United States Tax Court
34 T.C. 369; 1960 U.S. Tax Ct. LEXIS 144;
May 31, 1960, Filed
Decision will be entered for the petitioners.
The parents of the petitioner, Willy Zietz, were citizens of Germany. Hugo Zietz, the father, died testate in Germany in 1927. German law governs the construction of his will. Hugo in his will appointed his widow, Hedwig, the provisional heir of his estate for life and his sons the final or reversionary heirs to succeed their mother.…
2Cases cited14 opinions
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- Bowers v. LumpkinCourt of Appeals for the Fourth Circuit · 1944
- Levitt & Sons, Inc. v. NunanCourt of Appeals for the Second Circuit · 1944
- Coughlin v. CommissionerUnited States Tax Court · 1944
- Allen v. SeligCourt of Appeals for the Fifth Circuit · 1952
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