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ESTATE OF DAVEY v. COMMISSIONER

Docket No. 12341.

10 T.C. 515 (1948)

ESTATE OF ELIZABETH HAWXHURST DAVEY, DECEASED, ELIZABETH COVERDALE, DAVID MURRAY DAVEY AND MARY M. DAVEY, EXECUTORS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 24, 1948.

Attorney(s) appearing for the Case

William H. Harrar, Esq., for the petitioner.

Thomas R. Charshee, Esq., for the respondent.

Petitioner seeks a redetermination of an estate tax deficiency in the amount of $95.54 and claims an overpayment of estate tax in the amount of $4,001.77. The only question to be decided is whether certain funds arising from the liquidation of an inter vivos trust were deposited with a bank by or for a nonresident alien within the meaning of section 863 (b) of the Internal Revenue Code.

FINDINGS OF FACT.

Petitioner, an estate of a deceased nonresident alien...

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