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BURNET v. BROOKS

No. 496.

288 U.S. 378 (1933)

53 S.Ct. 457

77 L.Ed. 844

BURNET, COMMISSIONER OF INTERNAL REVENUE, v. BROOKS ET AL., EXECUTORS.

Supreme Court of United States.

Decided March 13, 1933.

Attorney(s) appearing for the Case

Solicitor General Thacher, with whom Assistant Attorney General Youngquist and Messrs. Sewall Key and J. Louis Monarch were on the brief, for petitioner.

Mr. Francis B. Hamlin, with whom Mr. Richard T. Greene was on the brief, for respondents.

MR. CHIEF JUSTICE HUGHES delivered the opinion of the Court.

Respondents contested the determination of the Commissioner of Internal Revenue in including in the gross estate of decedent certain intangible property. Decedent, who died in October, 1924, was a subject of Great Britain and a resident of Cuba. He was not engaged in business in the United States. The property in question consisted of securities, viz., bonds of...

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