Bonaparte v. Tax Court
104 U.S. 592 (1881)

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U.S. Supreme Court

Bonaparte v. Tax Court, 104 U.S. 592 (1881)

Bonaparte v. Tax Court

104 U.S. 592

Syllabus

The Constitution does not prohibit a state from including in the taxable property of her citizens so much of the registered public debt of another state as they respectively hold, although the debtor state may exempt it from taxation or actually tax it.

Mrs. Elizabeth Patterson, a resident of Baltimore, Md., returned, in accordance with the law of that state, to the proper board of assessors, the following property: City of New York stock, six percent; City of New York stock, seven percent; County of New York stock, seven percent; County of New York stock, six percent; State of New York stock, six percent; State of Pennsylvania stock, six percent; State of Ohio stock, six percent; and City of Philadelphia stock, six percent. She stated their several amounts and claimed their exemption from taxation because they were of a public character and, except a portion of the City of Philadelphia stock, were exempt from taxation by the laws of the states respectively authorizing their issue, while that portion had always been subjected by Pennsylvania to a tax which she had paid to that state. They were of the character known as "registered" -- i.e., transferable only on the public record books of the states and municipalities issuing them, and the interest was paid only at places provided by the laws of those states, and beyond the boundaries of Maryland. The board of control and review, by which this return was revised, disallowed her claim for exemption. She thereupon filed a petition in the Baltimore City Court, praying that the above-described property should be stricken from the lists. The order of the court granting the relief prayed was reversed by the Court of Appeals, whereupon she sued out this writ of error. She died during its pendency, and her executor was substituted in her stead.

Page 104 U. S. 594

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