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JANDORF'S ESTATE v. COMMISSIONER OF INTERNAL REVENUE

No. 13, Docket 20930.

171 F.2d 464 (1948)

JANDORF'S ESTATE v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Second Circuit.

December 21, 1948.

Attorney(s) appearing for the Case

Marvin Lyons, of New York City, George S. Fuller and Sumner H. Babcock, both of Boston, Mass., and D. Bret Carlson, of New York City, for petitioner.

Theron Lamar Caudle, Asst. Atty. Gen., and Robert M. Weston, George A. Stinson, Ellis N. Slack, and Maryhelen Wigle, Sp. Assts. to Atty. Gen., for respondent.

Before SWAN, CHASE, and FRANK, Circuit Judges.

SWAN, Circuit judge.

This appeal involves the federal estate tax of the estate of Karl Jandorf, a nonresident alien not engaged in business in the United States. At the date of his death on November 19, 1943, he was the beneficial owner of $150,000 of United States bonds physically located here, of which $75,000 were issued after March 1, 1941. The question for decision is whether the principal, plus accrued interest, of the bonds issued after March 1, 1941 was properly...

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