Commissioner v. Estate of Bosch, 387 U.S. 456 (1967)

Commissioner of Internal Revenue v. Estate of Bosch


No. 673


Argued March 22, 1967
Decided June 5, 1967 *
387 U.S. 456

CERTIORARI TO THE UNITED STATES COURT OF APPEALS
FOR THE SECOND CIRCUIT

Syllabus

Where federal estate tax liability turns upon the character of a property interest held and transferred by the decedent under State law, held, federal authorities are not bound by the determination made of such property interest by a state trial court; if there is no decision by the State’s highest court, federal authorities must apply what they find to be the state law after giving "proper regard" to relevant rulings of other courts of the State. Pp. 457, 462-466.

No. 673, 363 F.2d 1009, reversed and remanded; No. 240, 351 F.2d 489, affirmed.