Many American states have statutes limiting transmission of monies from estates in this country to citizens of countries behind the "Iron Curtain." American courts have come under heavy criticism for construing these statutes unfavorably to foreign heirs, especially where transmission to heirs in the Soviet Union is withheld. This article analyzes the relevant American and Soviet law and concludes that American courts, while they have not always been completely objective, nevertheless may be justified in withholding distribution from Soviet citizens.

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