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ESTATE OF JANDORF v. COMMISSIONER

Docket No. 9327.

9 T.C. 338 (1947)

ESTATE OF KARL JANDORF, THE FIRST NATIONAL BANK OF BOSTON, CUSTODIAN AND STATUTORY EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 12, 1947.

Attorney(s) appearing for the Case

Sumner H. Babcock, Esq., and George S. Fuller, Esq., for the petitioner.

William F. Evans, Esq., for the respondent.

Respondent determined a deficiency in estate tax in the amount of $7,940.39. Decedent was a nonresident alien, not engaged in business in the United States. The question is whether the value of certain United States Treasury bonds situated in the United States and beneficially owned by decedent is includible in the gross estate.

The estate tax returns were filed with the collector for the second district of New York.

FINDINGS OF FACT.

Some of the...

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