HINCKS, Circuit Judges.
This appeal involves the determination of the Federal Estate Tax on the estate of Elizabeth D. Holland, a non-resident British subject who died in Monte Carlo, Monaco, on February 1, 1948, not then engaged in business in the United States. Her estate included, in addition to assets abroad, bonds of the United States, issued after March 1, 1941, which at the date of death were physically located in the United States.
The Commissioner...
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