United States Supreme Court Cases & Opinions

U.S. Supreme Court

Lyeth v. Hoey, 305 U.S. 188 (1938)

Lyeth v. Hoey

No. 48

Argued November 16, 1938

Decided December 5, 1938

305 U.S. 188

Syllabus

1. Property received by an heir under an agreement compromising and settling his contest of the decedent's will is property acquired by "inheritance," within the meaning of § 22(b)(3) of the Revenue Act of 1932, which exempts the value of such property from the income tax. P. 305 U. S. 191.

2. This question is not determined by the local law, but is a federal question, in deciding which the language of the Revenue Law should be so construed as to give uniform application to a nationwide scheme of taxation. P. 305 U. S. 193.

Congress establishes its own criteria, and the state law may control only when the federal taxing Act, by express language or necessary implication, makes its operation dependent upon state law.

3. The claimant in this case was concededly an heir contesting the will. The decree of probate admitting the will also required that the estate be distributed in accordance with the compromise agreement. Insofar as it provided for distribution to heirs, the agreement overrode the will. The portion so obtained by the claimant came not through the will, but because of his heirship. The fact that he received less than the amount of his claim did not alter its nature or the quality of its recognition through the distribution which he did receive. What he got from the estate came to him because he was heir, the compromise serving to remove pro tanto the impediment to his inheritance. P. 305 U. S. 195.

96 F.2d 141 reversed; 20 F.Supp. 619 affirmed.

Certiorari, 304 U.S. 557, to review the reversal of judgment recovered from the respondent tax collector for money collected by him from the petitioner as an income tax.

Page 305 U. S. 189