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FILLMAN v. UNITED STATES

No. 541-58.

355 F.2d 632 (1966)

Henry I. FILLMAN, Ancillary Administrator of the Estate of Johann Heinrich Karl Wehrli, also known as Charles Wehrli v. The UNITED STATES.

United States Court of Claims.

January 21, 1966.

Attorney(s) appearing for the Case

Henry I. Fillman, New York City, attorney of record, for plaintiff.

Edna G. Parker, Tax Div., Dept. of Justice, Washington, D. C., with whom was Acting Asst. Atty. Gen. Richard M. Roberts, for defendant. C. Moxley Featherston, Lyle M. Turner, and Philip R. Miller, Washington, D. C., of counsel.

Before COWEN, Chief Judge, and LARAMORE, DURFEE, DAVIS and COLLINS, Judges.

COWEN, Chief Judge.

Plaintiff is the Ancillary Administrator of the estate of Charles Wehrli, deceased, who was a citizen and resident of Switzerland and who died on November 2, 1948. Plaintiff brought this action for the refund of Federal estate taxes and interest which were imposed pursuant to the provisions of Sections 811, 861, and 862 of the Internal Revenue Code of 1939, 26 U.S.C. §§ 811, 861, and 862 (1952...

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