Legal Opinion

Brooks v. Commissioner

United States Board of Tax Appeals

Decided February 5, 1931No. Docket No. 32401PublishedCited by 5 opinions

The decedent died on October 31, 1924, a citizen of Great Britain and a resident of Cuba. At the time of his death he was not engaged in business in the United States, but was possessed of certain intangible property, consisting of stock in a foreign corporation and bonds of foreign corporations, foreign governments, domestic corporations and of a domestic municipality, the paper evidences of which were located in New York City.

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The decedent died on October 31, 1924, a citizen of Great Britain and a resident of Cuba. At the time of his death he was not engaged in business in the United States, but was possessed of certain intangible property, consisting of stock in a foreign corporation and bonds of foreign corporations, foreign governments, domestic corporations and of a domestic municipality, the paper evidences of which were located in New York City. Said securities were deposited in part with decedent's son and in part with Lawrence Turnure & Company, for the sole purpose of having the income collected and…

1Opinion of the Court

*76OPINION.

Teammell :

The first issue for consideration in this proceeding is whether or not the value of intangible personal property of a nonresident alien decedent, comprising stock in a foreign corporation and bonds of foreign governments, foreign corporations, domestic corporations, and of a domestic municipality, should, for the purpose of the Federal estate tax be included under the facts of this case as a part of the decedent’s gross estate, which at the time of his death was “ situated in the United States.”

The decedent died on October 31, 1924, a resident of Cuba and a citizen of Great…

2Cases cited12 opinions

  1. Gould v. GouldSupreme Court of the United States · 1917
  2. Farmers Loan & Trust Co. v. MinnesotaSupreme Court of the United States · 1930
  3. Blackstone v. MillerSupreme Court of the United States · 1903
  4. Blodgett v. SilbermanSupreme Court of the United States · 1928
  5. Baldwin v. MissouriSupreme Court of the United States · 1930

7 more not listed; retrieve them via the Exa API.

3Cited by5 opinions

  1. Crocker v. CommissionerUnited States Board of Tax Appeals · 1933
  2. Brooks v. CommissionerUnited States Board of Tax Appeals · 1931
  3. Crocker v. CommissionerUnited States Board of Tax Appeals · 1933
  4. Garvan v. CommissionerUnited States Board of Tax Appeals · 1932
  5. St. Louis Union Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1932

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