De Perigny v. Commissioner
United States Tax Court
Value of 99-year leasehold interests (exchangeable for 999-year interests) in land situated in Kenya Colony, British East Africa, held excludible from decedent's gross estate for Federal estate tax purposes, as "real property situated outside of the United States," under Internal Revenue Code, sec. 811.
1Opinion of the Court
OPINION.
Opper, Judge:
Although the present controversy is argued broadly by the parties, and counsel deal ably and extensively with a wide range of topics, reaching from conflict of laws to the Hohfeldian analysis and from East Africa to Cuba, we find it unnecessary to go beyond a few narrow principles in disposing of the limited issue which seems to us presented by this record. The subject matter of the disputed application of Federal estate tax is a group of leases for 99 years, exchangeable at the lessee’s option for 999-year leases, of property located in Kenya Colony, British East Africa.…
2Cases cited8 opinions
- Helvering v. HallockSupreme Court of the United States · 1940
- J. W. Perry Co. v. City of NorfolkSupreme Court of the United States · 1911
- Wells v. Mayor of SavannahSupreme Court of Georgia · 1891
- Wells v. SavannahSupreme Court of the United States · 1901
- Ralston Steel Car Co. v. RalstonOhio Supreme Court · 1925
3 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- De Perigny v. CommissionerUnited States Tax Court · 1947
- Laird v. United StatesDistrict Court, W.D. Wisconsin · 1953