Watson v. State Comptroller, 254 U.S. 122 (1920)

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Watson v. State Comptroller

No. 26

Argued October 13, 1920
Decided November 15, 1920
254 U.S. 122

ERROR TO THE SURROGATE’S COURT OF NEW YORK COUNTY

STATE OF NEW YORK

Syllabus

In imposing transfer or inheritance taxes, a state may distinguish between property which has borne its fair share of tax burden in the decedent’s lifetime and property of the same kind, and passing to the same class of transferees, which has not. P. 124.

The additional tax imposed in New York (Cons.Laws, c. 60; Laws 1917, c. 700) on the transfer of certain kinds of securities held by a decedent at his death on which neither the general property tax nor the alternative stamp tax has been paid during a fixed period prior thereto is based upon a reasonable classification of property, and does not violate the equal protection clause of the Fourteenth Amendment. Id.

This tax is neither a property tax nor a penalty. P. 125.

226 N.Y. 384 affirmed.

The case is stated in the opinion.