Legal Opinion

Bradford-Martin v. Commissioner

United States Tax Court

Decided June 19, 1952No. Docket No. 29499Published

1. Held, that under the provisions of section 861 (c), I. R. C., United States bonds issued after March 1, 1941, are not includible in gross estate of petitioner's decedent who died before October 20, 1951, and who was at the time of his death a nonresident of the United States, not engaged in business within the United States. 2. Held, that bank deposits in a New York City bank to which petitioner's decedent, a nonresident of the United States acquired legal right as the…

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1. Held, that under the provisions of section 861 (c), I. R. C., United States bonds issued after March 1, 1941, are not includible in gross estate of petitioner's decedent who died before October 20, 1951, and who was at the time of his death a nonresident of the United States, not engaged in business within the United States. 2. Held, that bank deposits in a New York City bank to which petitioner's decedent, a nonresident of the United States acquired legal right as the sole heir at law under foreign law, and as residuary legatee, of a brother, a nonresident, who predeceased him, are deemed…

1Opinion of the Court

Estate of Mertyn S. Bradford-Martin, Deceased, Margaret Bradford-Martin, Administratrix, Petitioner, v. Commissioner of Internal Revenue, Respondent

Bradford-Martin v. Commissioner

Docket No. 29499

United States Tax Court

18 T.C. 544; 1952 U.S. Tax Ct. LEXIS 164;

June 19, 1952, Promulgated

Decision will be entered under Rule 50.

1. Held, that under the provisions of section 861 (c), I. R. C., United States bonds issued after March 1, 1941, are not includible in gross estate of petitioner's decedent who died before October 20, 1951, and who was at the time of his death a nonresident of the United…

2Cases cited10 opinions

  1. De Guebriant v. CommissionerUnited States Tax Court · 1950
  2. Jandorfs Estate v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1948
  3. Weiss v. CommissionerUnited States Tax Court · 1946
  4. Estate of Davey v. CommissionerUnited States Tax Court · 1948
  5. Gade v. CommissionerUnited States Tax Court · 1948

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