Loewenstein v. Commissioner
United States Tax Court
1. United States Treasury bonds issued after March 1, 1941, and held in trust for a nonresident alien, held, includible in her gross estate for estate tax purposes, following Estate of Karl Jandorf, 9 T. C. 338, and Estate of Irene de Guebriant, 14 T. C. 611. 2. 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…
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1. United States Treasury bonds issued after March 1, 1941, and held in trust for a nonresident alien, held, includible in her gross estate for estate tax purposes, following Estate of Karl Jandorf, 9 T. C. 338, and Estate of Irene de Guebriant, 14 T. C. 611. 2. 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. 3. Value of real estate determined for estate tax…
1Opinion of the Court
OPINION.
LeMire, Judge:
Our first question is whether the United States Government bonds, and accrued interest thereon, are includible in decedent’s gross estate under' section 811, Internal Bevenue Code. Petitioner contends that the bonds and interest are exempt from tax under section 750 of Title 31 of the United States Code, 1940 edition.1
Petitioner relies upon Jandorf's Estate v. Commissioner, 171 F. 2d 464. In that case the Court of Appeals for the Second Circuit held that the United States postwar bonds, as well as those issued before March 1, 1941, beneficially owned by nonresident…
2Cases cited12 opinions
- Plummer v. ColerSupreme Court of the United States · 1900
- United States Trust Co. v. HelveringSupreme Court of the United States · 1939
- Murdock v. WardSupreme Court of the United States · 1900
- De Guebriant v. CommissionerUnited States Tax Court · 1950
- Jandorfs Estate v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1948
7 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Bradford-Martin v. CommissionerUnited States Tax Court · 1952
- Bradford-Martin v. CommissionerUnited States Tax Court · 1952
- Loewenstein v. CommissionerUnited States Tax Court · 1951