Henry I. Fillman, Ancillary Administrator of the Estate of Johann Heinrich Karl Wehrli, Also Known as Charles Wehrli v. The United States

COWEN, Chief Judge.

Plaintiff is the Ancillary Administrator of the estate of Charles Wehrli, de ceased, who was a citizen and resident of Switzerland and who died on November 2, 1948. Plaintiff brought this action for the refund of Federal estate taxes and interest which were imposed pursuant to the provisions of Sections 811, 861, and 862 of the Internal Revenue Code of 1939, 26 U.S.C. §§ 811, 861, and 862 (1952 Ed.). 1 The question for decision is whether at the time of his death the decedent owned certain securities which were then in the physical possession of the Guaranty Trust Company…