Rivera v. Commissioner
United States Tax Court
Respondent has determined that the estate of a citizen of Puerto Rico who was also a citizen of the United States and who at the time of his death was domiciled in Puerto Rico should be taxed as that of a "nonresident not a citizen" pursuant to sections 860 to 865, I. R. C.Held, that the Federal estate tax is not applicable to a citizen of Puerto Rico who is also a citizen of the United States and who at the time of his death was domiciled in Puerto Rico, Estate of Albert…
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Respondent has determined that the estate of a citizen of Puerto Rico who was also a citizen of the United States and who at the time of his death was domiciled in Puerto Rico should be taxed as that of a "nonresident not a citizen" pursuant to sections 860 to 865, I. R. C.Held, that the Federal estate tax is not applicable to a citizen of Puerto Rico who is also a citizen of the United States and who at the time of his death was domiciled in Puerto Rico, Estate of Albert DeCaen Smallwood, 11 T. C. 740, followed, and the decedent was an American citizen who cannot be taxed as a nonresident…
1Opinion of the Court
Estate of Clotilde Santiago Rivera, Deceased, Guillermo E. Gonzalez and Jose Hernandez Usera, Executors, Petitioner, v. Commissioner of Internal Revenue, Respondent
Rivera v. Commissioner
Docket No. 36335
United States Tax Court
19 T.C. 271; 1952 U.S. Tax Ct. LEXIS 38;
November 21, 1952, Promulgated
Decision will be entered for the petitioner.
Respondent has determined that the estate of a citizen of Puerto Rico who was also a citizen of the United States and who at the time of his death was domiciled in Puerto Rico should be taxed as that of a "nonresident not a citizen" pursuant to sections 860 to…
2Cases cited3 opinions
- Balzac v. Porto RicoSupreme Court of the United States · 1922
- Smallwood v. CommissionerUnited States Tax Court · 1948
- Rivera v. CommissionerUnited States Tax Court · 1952