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the basis of decedent's status as a resident alien during those
years.
On the Form 706, United States Estate Tax Return, petitioner
indicated that decedent's domicile at the time of death was Butte
City, California, and that decedent established the domicile in
1985. Most of decedent's business and property interests were
located in the United States. At the time of decedent's death,
those interests were valued at approximately $746,000. Decedent
also maintained bank accounts in the United States.10 At the
time of his death the value of the deposits in his bank accounts
was over $70,000. The only property decedent owned in Pakistan
was the 15-acre farm, valued at $15,000 at the time of his death.
In computing the Federal estate tax, petitioner claimed a unified
credit of $192,800.
Respondent determined that decedent was not a resident of
the United States on the date of his death and limited
petitioner's unified credit to $13,000.
OPINION
Section 2001 imposes a transfer tax on the taxable estate
(determined under section 2053) of every decedent who is a
citizen or resident of the United States. Section 2010 permits a
credit of $192,800 against the estate tax imposed by section
10 Decedent maintained a bank account in the United States
as early as 1976.
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