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
Estate of Fredericka Loewenstein, Deceased, Max S. Lowenstein, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent. *
Loewenstein v. Commissioner
Docket No. 25414
United States Tax Court
16 T.C. 1152; 1951 U.S. Tax Ct. LEXIS 183;
May 24, 1951, Promulgated
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…
2Cases cited13 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
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