District Court, S.D. New York January 3, 1947, Civ. No. 32-415 (City Bank Farmers Trust Co. v. Pedrick)

BYERS, District Judge.

The question for decision is whether Section 863(b) of the Internal Revenue Code, 26 U.S.C.A. Int.Rev.Code, § 863(b), applies to the bank account hereinafter described so that it is not to be deemed property within the United States, for estate taxation.

The statute reads:

“ § 863.