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SIEGEL v. UNITED STATES

No. 42616.

18 F.Supp. 771 (1937)

SIEGEL et al. v. UNITED STATES.

Court of Claims.

April 5, 1937.

Attorney(s) appearing for the Case

Harry S. Hall, of New York City, for plaintiffs.

Elizabeth B. Davis, of Washington, D. C., and Robert H. Jackson, Asst. Atty. Gen., for the United States.

Before BOOTH, Chief Justice, and GREEN, LITTLETON, WILLIAMS, and WHALEY, Judges.

LITTLETON, Judge.

The principal question in this case is whether this suit was barred at the time it was instituted. We are of opinion that it was not. Section 403 (b) (2) and (3) of the Revenue Act of 1921 provided, so far as pertinent here, as follows:

"In the case of a nonresident, by deducting from the value of that part of his gross estate which at the time of his death is situated in the United States * *...

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