Tyler v. United States
281 U.S. 497 (1930)

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U.S. Supreme Court

Tyler v. United States, 281 U.S. 497 (1930)

Tyler v. United States

Nos. 428, 546 and 547

Argued April 24, 1930

Decided May 19, 1930

281 U.S. 497

Syllabus

1. The power of Congress to impose a tax in the event of death does not depend upon whether there has been a "transfer" of property by the death of the decedent, but whether the death has brought into being or ripened for the survivor property rights of such character as to make appropriate the imposition of a tax upon that result (which Congress may call a transfer tax, a death duty, or anything else it sees fit), to be measured in whole or in part by the value of such rights. P. 281 U. S. 502.

2. The inclusion of property held by husband and wife as tenants by the entirety, no part of which originally belonged to the survivor, in the gross estate of the decedent spouse for the purpose of computing the tax "upon the transfer of the net estate" imposed by the Revenue Acts of 1916 and 1921, §§ 201-202, does not result in imposing a direct tax in violation of the constitutional requirement of apportionment. Const. Art. I, § 2, cl. 3, and § 9, cl. 4. Pp. 281 U. S. 503-504

3. To include in the gross estate of a decedent, for the purpose of computing the tax "upon the transfer of the net estate," the value of property held by him and another as tenants by the entirety, where such property originally belonged in no part to the survivor but came to the tenancy as a pure gift from the decedent, is neither arbitrary nor capricious, and does not violate the due process clause of the Fifth Amendment. P. 281 U. S. 504.

4. The evident and legitimate aim of Congress was to prevent an avoidance, in whole or in part, of the estate tax by this method of

Page 281 U. S. 498

disposition during the lifetime of the spouse who owned the property, or whose separate funds had been used to procure it, and the provision under review is an adjunct of the general scheme of taxation of which it is a part, entirely appropriate as a means to that end. P. 281 U. S. 505.

33 F.2d 724, reversing 28 F.2d 887, affirmed.

35 F.2d 339 and 35 F.2d 343, reversed.

Certiorari, 280 U.S. 548, , to review judgments of the circuit courts of appeals in three cases involving the constitutionality of the federal estate tax in respect of the provisions requiring the inclusion of the interests of tenants by the entirety in the gross estate.

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