Pulvermann v. Commissioner
United States Tax Court
Held, bonds of a New Jersey corporation, which were owned by a nonresident alien at the time of their destruction in England, were not situated in the United States within the meaning of section 861 (a), I. R. C. 1939, at the time of the alien's death abroad some 3 years later.
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Held, bonds of a New Jersey corporation, which were owned by a nonresident alien at the time of their destruction in England, were not situated in the United States within the meaning of section 861 (a), I. R. C. 1939, at the time of the alien's death abroad some 3 years later. Held, further, under the facts, the bonds were not physically situated in the United States at the time decedent made a revocable transfer of the bonds to his son, within the provisions of section 862 (b), I. R. C. 1939.
1Opinion of the Court
OPINION.
MulRoney, Judge:
The respondent determined estate tax in the sum of $17,199-32 as due from petitioner, Curt E. Pulvermann, as a beneficiary of, and transferee of, the Estate of Eduard F. Pulvermann, Deceased.
The questions presented are whether certain bonds of a New Jersey corporation were situated in the United States at the time a nonresident alien decedent died or at the time said decedent made a revocable transfer of the bonds to petitioner.
All of the facts were stipulated and are found accordingly.
Eduard F. Pulvermann, hereinafter called decedent, was a citizen and resident of…
2Cases cited4 opinions
- Burnet v. BrooksSupreme Court of the United States · 1933
- New York Ex Rel. New York Central & Hudson River Railroad v. MillerSupreme Court of the United States · 1906
- Delaney v. MurchieCourt of Appeals for the First Circuit · 1949
- Nicholson v. NicholsonMontana Supreme Court · 1923
3Cited by2 opinions
- Estate of Paquette v. CommissionerUnited States Tax Court · 1983
- Pulvermann v. CommissionerUnited States Tax Court · 1958