Legal Opinion

Lyman v. Commissioner

United States Board of Tax Appeals

Decided June 3, 1931No. Docket No. 34275Published

Section 319 of the Revenue Act of 1924, levying a tax upon gifts of property "wherever situated," held not to apply to gifts or real property situated outside the United States.

1Opinion of the Court

ELIZABETH W. LYMAN AND WILLIAM H. LYMAN, JR., EXECUTORS OF THE WILL OF WILLIAM H. LYMAN, DECEASED, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Lyman v. Commissioner

Docket No. 34275.

United States Board of Tax Appeals

23 B.T.A. 540; 1931 BTA LEXIS 1856;

June 3, 1931, Promulgated

Section 319 of the Revenue Act of 1924, levying a tax upon gifts of property "wherever situated," held not to apply to gifts or real property situated outside the United States.

P. B. Plumb, Esq., for the petitioners.

J. L. Backstrom, Esq., for the respondent.

MATTHEWS

This is a proceeding for the…

2Cases cited3 opinions

  1. Bromley v. McCaughnSupreme Court of the United States · 1929
  2. Guaranty Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1930
  3. Lyman v. CommissionerUnited States Board of Tax Appeals · 1931

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