ESTATE OF GUEBRIANT v. COMMISSIONER

Docket No. 17081.

14 T.C. 611 (1950)

ESTATE OF IRENE DE GUEBRIANT, DECEASED, AVERY CLAFLIN AND PHILIP A. CARROLL, EXECUTORS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 18, 1950.


Attorney(s) appearing for the Case

E. L. Finnan, Esq., for the petitioner.

E. Randolph Dale, Esq., for the respondent.


Respondent determined a deficiency of $11,651.31 in the estate tax of petitioner's decedent, who was a nonresident alien not engaged in business in the United States at the time of her death. Petitioner presents three questions for our decision:

(1) Were one-half of certain trust funds deposited in the name of the trustees in a New York bank to which the decedent was entitled as a remainderman excludable from her gross estate as a deposit "by or for" her within the...

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