Guaranty Trust Co. v. Commissioner
United States Board of Tax Appeals
The facts herein show that decedent was a resident of the United States within the meaning of section 301(a) of the Revenue Act of 1924, as amended by section 322 of the Revenue Act of 1926.
1Opinion of the Court
*509OPINION.
Trammell :
The first issue is whether the respondent erred in determining that the decedent was a resident of the State of New York and thus a resident of the United States within the meaning of section 301 (a) of the Revenue Act of 1924, as amended by section 322 of the Revenue Act of 1926, effective as of June 2, 1924. That section provides as follows:
In lieu of the tax imposed by Title IV of the Revenue Act of 1921, a tax equal to the sum of the following percentages of the value of the net estate (deter*510mined as provided in section 303) is hereby imposed upon tbe transfer of tbe net…
2Cases cited2 opinions
- Bullen v. WisconsinSupreme Court of the United States · 1916
- Frick Et Al. v. PennsylvaniaSupreme Court of the United States · 1925
3Cited by4 opinions
- Fifth Ave. Bank v. CommissionerUnited States Board of Tax Appeals · 1937
- Guaranty Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1932
- Rodiek v. CommissionerUnited States Board of Tax Appeals · 1936
- St. Louis Union Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1932