Dorothy Gould Burns

Dorothy Gould Burns (1904 – July 6, 1969), known as Countess de Graffenried de Villars, was the subject of a court case concerning when a United States citizen who lives overseas has undergone expatriation or has become a dual national and thus still subject to United States taxation.

Dorothy Gould was the granddaughter of the railroad magnate Jay Gould. She was born in the United States in 1904 to Frank Jay Gould and Helen Margaret Kelly. In 1919 she left the United States for Europe, and she never re-established a legal residence in the United States.

On May 5, 1925 she married a Swiss citizen, Baron Roland Graffenried de Villars. Roland was the third son of Count Friedrich Johann Prosper Graffenried de Villars and Countess de Diesbach-Belleroche.

They had two daughters and divorced in 1936. During this period she traveled as a citizen of the United States using a United States passport which expired in 1934. The United States Department of State refused to renew her United States passport, so she traveled under an "affidavit in lieu of passport" issued by the American Consulate in Switzerland. When the Germans occupied France, she returned to the United States in 1941 on a newly issued United States passport. She remained only briefly and entered Cuba where she met her second husband, Archibald Burns, a Mexican national of Scottish parents. She traveled with him to Mexico where they married in 1944.

She died on July 6, 1969. When her estate's executor applied for a $24,000 refund relating to certain gift and income taxes she had paid on the grounds that she had abandoned US citizenship, the Internal Revenue Service disputed the claim, asserting that the abandonment never took place, and her estate was thus also liable to $3.25 million in estate tax. The US position was upheld by the United States District Court for the Southern District of New York, and subsequently affirmed by the United States Court of Appeals for the Second Circuit. The Second Circuit held that the estate could not succeed in its claim, because of the doctrines of estoppel and laches that arose out of her assertions that she had remained an American citizen.

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