Dorothy Gould Burns (March 24, 1904 – July 6, 1969), known as Baroness Dorothy 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.
Her sister, Helen Marguerite Gould, was the wife of Raymond, Baron of Montenach.
She remained only briefly and entered Cuba where she met her second husband, Archibald Burns, a Mexican national of Scottish parents.
[citation needed] 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.