In a comment appearing in the May issue of the Review (30 MICH. L. REV. 1094), this writer considered the existing conflict of decisions on the question of a receiver's liability for corporate franchise taxes accruing during the period of receivership. The opposing views, as represented by In Re Detroit Properties Co., 254 Mich. 523, 236 N. W. 850 (1931), and Michigan Trust Co. v. Michigan (C. C. A. 6th, 1931) 52 F.(2d) 842, were compared and evaluated. Both decisions were based on the same Michigan statute (2 Comp. Laws 1929, sec. 10140). It was pointed out that the Michigan Trust Co. case was before the United States Supreme Court on a writ of certiorari, and this writer expressed a hope that the forthcoming holding would result in a clarification of the law on the subject. Since publication of the May number, the Supreme Court has acted, reversing the Circuit Court of Appeals and holding the tax collectible. Michigan v. Michigan Trust Co., U. S. Sup. Ct. Adv. Op. No. 598 (May 16, 1932). 7 U. S. Daily 517 (May 17, 1932).