Beers v. Glynn, 211 U.S. 477 (1909)

Beers v. Glynn


No. 45


Argued December 9, 1908
Decided January 4, 1909
211 U.S. 477

ERROR TO THE SURROGATE’S COURT OF THE
COUNTY OF NEW YORK, STATE OF NEW YORK

Syllabus

So far as the federal Constitution is concerned, the power of the state in respect to taxation is very broad, and includes exemption of certain classes of property from taxation to which other property is subjected, and different classes may be taxed by different methods of procedure without violating the due process and equal protection provisions of the Fourteenth Amendment.

The provisions in the New York Inheritance Tax Law, c. 713 of Laws of 1887, amending c. 483 of the Laws of 1887, for taxing personalty of nonresident decedents who had owned realty in that state, are not unconstitutional as denying to those interested in estates of that class of decedents due process or equal protection of the laws, because no provision is made for taxing personalty of nonresident decedents who had not owned any realty in New York.

The facts, which involve the constitutionality of §§ 1 and 15 of the New York Inheritance Tax Law, are stated in the opinion.