United States Supreme Court Cases & Opinions

U.S. Supreme Court

New York Trust Co. v. Eisner, 256 U.S. 345 (1921)

New York Trust Company v. Eisner

No. 286

Argued April 25, 26, 1921

Decided May 16, 1921

256 U.S. 345

Syllabus

1. The Act of September 8, 1916, c. 463, Title II, § 201 et seq., 39 Stat. 777, imposes a tax on the transfer of the net estate of every decedent, graduated according to the value as ascertained by deducting, in the case of a resident, from the gross estate, funeral, administration and other expenses and charges, and a specified exemption; the tax is due in one year from the decedent's death, is payable primarily by the personal representative, and is made a lien upon the gross estate except such part as is paid out for allowed charges, etc. Held, an indirect tax, not requiring apportionment, and not an unconstitutional interference with the rights of the states to regulate descent and distribution. P. 256 U. S. 348. Knowlton v. Moore, 178 U. S. 41.

2. That the tax may occasion inequalities in amounts received by beneficiaries does not affect its validity. P. 256 U. S. 349.

3. "Charges against the estate," deductible under § 203 of the act in computing net value, affect the estate as a whole, and therefore do not include state inheritance and succession taxes on the shares of individual beneficiaries. P. 256 U. S. 350.

263 F.6d 0 affirmed.

The case is stated in the opinion.

Page 256 U. S. 346