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. See also Citizenship in the United States United States nationality law References 1904 births 1969 deaths United States nationality law History of taxation in the United States Personal taxes in the United States Inheritance tax Wealth in the United States United States taxation and revenue case law Dorothy Swiss nobility