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COMMISSIONER v. ESTATE OF BOSCH

No. 673.

387 U.S. 456 (1967)

87 S.Ct. 1776

18 L.Ed.2d 886

COMMISSIONER OF INTERNAL REVENUE v. ESTATE OF BOSCH.

Supreme Court of United States.

Decided June 5, 1967.

Attorney(s) appearing for the Case

Jack S. Levin argued the cause for petitioner in No. 673 and for the United States in No. 240. With him on the briefs were Acting Solicitor General Spritzer, Assistant Attorney General Rogovin, Richard C. Pugh, Meyer Rothwacks, Robert N. Anderson and Thomas Silk, Jr.

Curtiss K. Thompson argued the cause for petitioner in No. 240. With him on the briefs was John H. Weir.

John W. Burke, Jr., argued the cause and filed a brief for respondent in No. 673.

MR. JUSTICE CLARK delivered the opinion of the Court.

These two federal estate tax cases present a common issue for our determination: Whether a federal court or agency in a federal estate tax controversy is conclusively bound by a state trial court adjudication of property rights or characterization of property interests when the United States is not made a party to such proceeding.

In No. 673, Commissioner of...

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