Legal Opinion

Estate of Loewenstein v. Commissioner

United States Tax Court

Decided July 23, 1951No. Docket No. 25414Published

1. Funds held by a resident trustee in the general bank account of the trust for the benefit of a nonresident alien, the sole life beneficiary, held, not excludible from her gross estate as bank deposits "by or for" a nonresident alien, within the meaning of section 863 (b), I. R. C. 2. Value of real estate determined for estate tax purposes.

1Opinion of the Court

Estate of Fredericka Loewenstein, Deceased, Max S. Lowenstein, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent

Estate of Loewenstein v. Commissioner

Docket No. 25414

United States Tax Court

17 T.C. 60; 1951 U.S. Tax Ct. LEXIS 124;

July 23, 1951, Promulgated

Decision will be entered under Rule 50.

1. Funds held by a resident trustee in the general bank account of the trust for the benefit of a nonresident alien, the sole life beneficiary, held, not excludible from her gross estate as bank deposits "by or for" a nonresident alien, within the meaning of section 863 (b), I. R. C.

2.…

2Cases cited8 opinions

  1. De Guebriant v. CommissionerUnited States Tax Court · 1950
  2. Jandorfs Estate v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1948
  3. Weiss v. CommissionerUnited States Tax Court · 1946
  4. Estate of Davey v. CommissionerUnited States Tax Court · 1948
  5. Gade v. CommissionerUnited States Tax Court · 1948

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