United States v. The Montreal Trust Company, and Tillie v. Lechtzier, Executors of the Estateof Isidor J. Klein, Deceased

Question Presented

The question presented on this appeal is whether the United States government, in an action to recover income taxes, interest and penalties aggregating $9,-862,053.34 based on tax liabilities assessed in absentia 11 years ago and claimed to have arisen 20 years ago by reason of the alleged constructive receipt in Canada of income from United States sources, may, under the New York long arm statute, invoke the jurisdiction of the District Court for the Southern District of New York, by process served in Vancouver, British Columbia, Canada, over a Canadian banking institution…