256 U.S. 345 (1921), 286, New York Trust Company v. Eisner

Docket Nº:No. 286
Citation:256 U.S. 345, 41 S.Ct. 506, 65 L.Ed. 963
Party Name:New York Trust Company v. Eisner
Case Date:May 16, 1921
Court:United States Supreme Court
 
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Page 345

256 U.S. 345 (1921)

41 S.Ct. 506, 65 L.Ed. 963

New York Trust Company

v.

Eisner

No. 286

United States Supreme Court

May 16, 1921

Argued April 25, 26, 1921

ERROR TO THE DISTRICT COURT OF THE UNITED STATES

FOR THE SOUTHERN DISTRICT OF NEW YORK

Syllabus

1. The Act of September 8, 1916, c. 463, Title II, § 201 et seq., 39 Stat. 777, imposes a tax on the transfer of the net estate of every decedent, graduated according to the value as ascertained by deducting, in the case of a resident, from the gross estate, funeral, administration and other expenses and charges, and a specified exemption; the tax is due in one year from the decedent's death, is payable primarily by the personal representative, and is made a lien upon the gross estate except such part as is paid out for allowed charges, etc. Held, an indirect tax, not requiring apportionment, and not an unconstitutional interference with the rights of the states to regulate descent and distribution. P. 348. Knowlton v. Moore, 178 U.S. 41.

2. That the tax may occasion inequalities in amounts received by beneficiaries does not affect its validity. P. 349.

3. "Charges against the estate," deductible under § 203 of the act in computing net value, affect the estate as a whole, and therefore do not include state inheritance and succession taxes on the shares of individual beneficiaries. P. 350.

263 F. 620 affirmed.

The case is stated in the opinion.

Page 346

HOLMES, J., lead opinion

MR. JUSTICE HOLMES delivered the opinion of the Court.

This is a suit brought by the executors of one Purdy to recover an estate tax levied under the Act of Congress of September 8, 1916, c. 463, Title II, § 201, 39 Stat. 756, 777, and paid under duress on December 14, 1917. According to the complaint, Purdy died leaving a will and codicil directing that all succession, inheritance, and transfer taxes should be paid out of the residuary estate, which was bequeathed to the descendants of his brother. The value of the residuary estate was $427,414.96, subject to some administration expenses. The executors had been required to pay and had paid inheritance and succession taxes to New York ($32,988.97) and other states ($4,780.91) amounting in all to $37,769.88. The gross estate as defined in § 202 of the Act of Congress was $769,799.39; funeral expenses and expenses of administration, except the above taxes...

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