TAXATION-SITUS OF INTANGIBLES FOR SUCCESSION TAX

Authors

Abstract

Decedent died domiciled in Connecticut, leaving as part of his estate, bonds and treasury certificates of the United States, which at the time of his death, and for a long time prior thereto had been physically placed and kept in safety deposit vaults in New York city, and had never been in Connecticut. The superior court of Fairfield county, on the advice of the supreme court of errors of Connecticut held that the bonds and certificates were not subject to a succession tax in Connecticut at the domicil of the decedent. The supreme court reached its decision by applying its conception of the principle underlying the holding in Frick v. Pennsylvania. The case was taken to the United States Supreme Court, which held that bonds and certificates of the United States were taxable at the domicil of the decedent. The court said they were undistinguishable from any other choses in action, being merely evidences of the debts.

Recommended Citation

TAXATION-SITUS OF INTANGIBLES FOR SUCCESSION TAX, 27 Mich. L. Rev. 447 (1929).
Available at: https://repository.law.umich.edu/mlr/vol27/iss4/7