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ESTATE OF BLOCH-SULZBERGER v. COMMISSIONER

Docket No. 10216.

6 T.C.M. 1201 (1947)

Estate of Julius Bloch-Sulzberger, Paul Schrag and Dulcie Bloch-Sulzberger, Executors v. Commissioner.

United States Tax Court.

November 12, 1947.

Attorney(s) appearing for the Case

Randolph E. Paul, Esq., and Louis Eisenstein, Esq., for the petitioners. Henry C. Clark, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined a deficiency of $73,162.70 in estate tax. The first question for decision is whether the decedent was a resident of the United States at the time of his death so that his estate was taxable under Part II, Subchapter A of Chapter 3, or whether he was not a resident within the meaning of that provision and, therefore, his estate was taxable under Part III. The other issue for decision is whether a...

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