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ESTATE OF LOEWENSTEIN v. COMMISSIONER

Docket No. 25414.

16 T.C. 1152 (1951)

ESTATE OF FREDERICKA LOEWENSTEIN, DECEASED, MAX S. LOWENSTEIN, EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 24, 1951.

Attorney(s) appearing for the Case

Kenneth Carroad, Esq., and Herbert D. Cohen, Esq., for the petitioner.

Pershing W. Burgard, Esq., for the respondent.

This proceeding involves an estate tax deficiency of $17,436.36. The issues are (1) whether certain United States bonds with accrued interest are excludible from the gross estate under section 4 of the Victory Liberty Loan Act of 1919, (2) whether certain funds of an irrevocable trust created by decedent, a nonresident alien, are excludible from the gross estate as bank deposits by or for a nonresident alien within the meaning of section 863 (b), Internal Revenue Code, and...

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