Garvan v. Commissioner
United States Board of Tax Appeals
1. Where paper evidences of shares of stock of a foreign corporation and bonds of foreign governments belonging to a nonresident alien were held within the United States for certain restricted purposes, such stock and bonds may not be included for purposes of taxation in the estate of such nonresident alien, because they were not property situated within the United States within the meaning of the statute.
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1. Where paper evidences of shares of stock of a foreign corporation and bonds of foreign governments belonging to a nonresident alien were held within the United States for certain restricted purposes, such stock and bonds may not be included for purposes of taxation in the estate of such nonresident alien, because they were not property situated within the United States within the meaning of the statute. Ernest Brooks et al.,22 B.T.A. 71, followed. 2. Shares of stock of domestic corporations, similarly owned and held, may be included in decedent's estate by authority of section 303(d) of…
1Opinion of the Court
ESTATE OF JOHN JOSEPH GARVAN, THE FIRST NATIONAL BANK OF BOSTON, ADMINISTRATOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Garvan v. Commissioner
Docket No. 44746.
United States Board of Tax Appeals
25 B.T.A. 612; 1932 BTA LEXIS 1495;
February 25, 1932, Promulgated
1. Where paper evidences of shares of stock of a foreign corporation and bonds of foreign governments belonging to a nonresident alien were held within the United States for certain restricted purposes, such stock and bonds may not be included for purposes of taxation in the estate of such nonresident alien, because…
2Cases cited51 opinions
- M'culloch v. State of MarylandSupreme Court of the United States · 1819
- Hurtado v. CaliforniaSupreme Court of the United States · 1884
- Hilton v. GuyotSupreme Court of the United States · 1895
- Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
- Brushaber v. Union Pacific RailroadSupreme Court of the United States · 1916
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