Baldwin v. Missouri, 281 U.S. 586 (1930)

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Baldwin v. Missouri


No. 417


Argued April 23, 1930
Decided May 26, 1930
281 U.S. 586

ERROR TO AND APPEAL FROM
THE SUPREME COURT OF MISSOURI

Syllabus

A resident of Illinois, dying there, willed all her property to her son, also a resident of that state. The will was probated in Illinois, and an inheritance tax was there laid upon all her intangible personalty, wherever situate. At the time of her death, she owned credits for cash deposited in banks located in Missouri, and coupon bonds of the United States and promissory notes, all physically within that state. Some of the notes had been executed by citizens of Missouri, and some were secured on lands there. Held that the credits, bonds, and notes were not within the jurisdiction of Missouri for taxation purposes, and that to enforce Missouri transfer or inheritance taxes reckoned upon their value would violate the due process clause of the Fourteenth Amendment. P. 591.

323 Mo. 207 reversed.

Appeal from a judgment of the Supreme Court of Missouri, which reversed a judgment of the state Circuit Court and sustained an inheritance tax, assessed by the Probate Court, which the Circuit Court, on appeal, had found invalid.