United States Supreme Court Cases & Opinions

U.S. Supreme Court

Billings v. Illinois, 188 U.S. 97 (1903)

Billings v. Illinois

No. 106

Argued December 4, 1902

Decided January 19, 1903

188 U.S. 97

Syllabus

The claim that section 2 of the act providing for the taxation of life estates, as construed by the highest courts of the Illinois, is in contravention of the Fourteenth Amendment in that the classification of life tenants is arbitrary and unreasonable and denies to life tenants the equal protection of laws because it taxes one class of life estates where the remainder is to lineals and expressly exempts life estates where the remainder is to collaterals or to strangers in blood, cannot be sustained.

Inheritance tax laws are based upon the power of a state over testate and intestate dispositions of property, to limit and create estates, and to impose conditions upon their transfer or devolution. This Court has already decided in regard to this law that such power could be exercised by distinguishing between the lineal and collateral relatives of a testator.

Page 188 U. S. 98

Whether the amount of the tax depends upon him who immediately receives or upon him who ultimately receives makes no difference with the power of the state. No discrimination being exercised in the creation of the class, equality is observed. Magoun v. Illinois Trust and Savings Bank, 170 U. S. 283, followed.

The case is stated in the opinion of the Court.