Guaranty Trust Co. v. Commissioner
United States Board of Tax Appeals
ESTATE TAX. - In valuing the gross estate of a resident decedent it is proper to include the value of tangible personal property located in foreign countries.
1Opinion of the Court
opinion.
ARUNdell:
Decedent herein at the time of her death was a resident of the United States owning tangible property in foreign countries which property respondent has included in the gross estate. The revenue act in effect at the time of death was that of 1924, which, in section 302, provides:
Sec. 302. The value of the gross estate of the decedent shall be determined by including the value at the time of his death of all property, real or personal, tangible or intangible, wherever situated * * *.
This language has appeared in all of the revenue acts beginning with that of September 8, 1916.…
2Cases cited3 opinions
- Frick v. PennsylvaniaSupreme Court of the United States · 1925
- Cook v. TaitSupreme Court of the United States · 1924
- United States v. BennettSupreme Court of the United States · 1914
3Cited by4 opinions
- Cromwell v. CommissionerUnited States Board of Tax Appeals · 1931
- Fair v. CommissionerUnited States Board of Tax Appeals · 1936
- Guaranty Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1930
- Lyman v. CommissionerUnited States Board of Tax Appeals · 1931