Bradford-Martin v. Commissioner
United States Tax Court
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
OPINION.
Hareon, Judge:
This proceeding arises from a determination of a deficiency in estate tax in the amount of $1,823.87. An estate tax return for the decedent’s estate was filed with the collector for the second district of New York.
The facts are not in dispute. The parties have filed a stipulation of all of the facts.
Mertyn S. Bradford-Martin and Benjamin R. Bradford-Martin were brothers; both were nonresident aliens having their domicile in the Island of Jersey, one of the Channel Islands in the English Channel, both were British subjects; and both at the times of their respective deaths…
2Cases cited9 opinions
- De Guebriant v. CommissionerUnited States Tax Court · 1950
- Jandorfs Estate v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1948
- Weiss v. CommissionerUnited States Tax Court · 1946
- Estate of Davey v. CommissionerUnited States Tax Court · 1948
- Gade v. CommissionerUnited States Tax Court · 1948
4 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Oei Tjong Swan v. CommissionerUnited States Tax Court · 1955
- Worthington v. CommissionerUnited States Tax Court · 1952
- Bank of New York v. United StatesDistrict Court, S.D. New York · 1957
- Estate of Ogarrio (Daguerre) v. CommissionerUnited States Tax Court · 1963
- Bradford-Martin v. CommissionerUnited States Tax Court · 1952
3 more not listed; retrieve them via the Exa API.