An American citizen and resident died while temporarily in England leaving property in the United States, which was disposed of by an American will, and property consisting of tangible and intangible personalty in EngIand, which was disposed of by an English will. The executors of the English will paid the English death duties. The United States claimed that the English property should be included in the whole estate subject to the United States estate tax; this the executors of the American will denied, claiming that the United States had no jurisdiction to tax this property. Held, that the language of the statute clearly included this property and that the fact of the decedent's being a citizen and resident of the United States was a sufficient jurisdictional basis for the tax. Guaranty Trust Co. of New York v. Commissioner of Internal Revenue, (C. C. A. 2d, 1935) 79 F. (2d) 245.