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ESTATE OF LOCKIE v. COMMISSIONER

Docket No. 32102.

21 T.C. 64 (1953)

ESTATE OF GEORGE McNAUGHT LOCKIE, DECEASED, GUARANTY TRUST COMPANY OF NEW YORK, ANCILLARY EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 15, 1953.

Attorney(s) appearing for the Case

Edgar A. Kniffin, Esq., and Horace N. Taylor, Esq., for the petitioner.

Clay C. Holmes, Esq., for the respondent.

The Commissioner determined a deficiency of $42,905.41 in estate tax. The issues for decision are:

(1) Whether the value of a dividend on General Electric stock declared prior to the death of the decedent but payable to stockholders of record on the day after his death is includible in the gross estate,

(2) Whether loans of $111,200 and 5,000 shares of stock of the Bank of Nova Scotia had siti in the United States...

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