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Tyler v. United States, 281 U.S. 497 (1930)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Tyler v. United States, 281 U.S. 497 (1930)
Tyler v. United States Nos. 428 , 546 and 547 Argued April 24, 1930 Decided May 19, 1930 281 U.S. 497
CERTIORARI TO THE CIRCUIT COURTS OF APPEALS
FOR THE FOURTH AND THIRD CIRCUITS
Syllabus
1. The power of Congress to impose a tax in the event of death does not depend upon whether there has been a "transfer" of property by the death of the decedent, but whether the death has brought into being or ripened for the survivor property rights of such character as to make appropriate the imposition of a tax upon that result (which Congress may call a transfer tax, a death duty, or anything else it sees fit), to be measured in whole or in part by the value of such rights. P. 502.
2. The inclusion of property held by husband and wife as tenants by the entirety, no part of which originally belonged to the survivor, in the gross estate of the decedent spouse for the purpose of computing the tax "upon the transfer of the net estate" imposed by the Revenue Acts of 1916 and 1921, §§ 201-202, does not result in imposing a direct tax in violation of the constitutional requirement of apportionment. Const. Art. I, § 2, cl. 3, and § 9, cl. 4. Pp. 503-504
3. To include in the gross estate of a decedent, for the purpose of computing the tax "upon the transfer of the net estate," the value of property held by him and another as tenants by the entirety, where such property originally belonged in no part to the survivor but came to the tenancy as a pure gift from the decedent, is neither arbitrary nor capricious, and does not violate the due process clause of the Fifth Amendment. P. 504.
4. The evident and legitimate aim of Congress was to prevent an avoidance, in whole or in part, of the estate tax by this method of disposition during the lifetime of the spouse who owned the property, or whose separate funds had been used to procure it, and the provision under review is an adjunct of the general scheme of taxation of which it is a part, entirely appropriate as a means to that end. P. 505.
33 F.2d 724, reversing 28 F.2d 887, affirmed.
35 F.2d 339 and 35 F.2d 343, reversed.
Certiorari, 280 U.S. 548, , to review judgments of the circuit courts of appeals in three cases involving the constitutionality of the federal estate tax in respect of the provisions requiring the inclusion of the interests of tenants by the entirety in the gross estate.
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Chicago: U.S. Supreme Court, "Syllabus," Tyler v. United States, 281 U.S. 497 (1930) in 281 U.S. 497 281 U.S. 498. Original Sources, accessed November 22, 2024, http://originalsources.com/Document.aspx?DocID=NYA2ZF8ZRPUBN3E.
MLA: U.S. Supreme Court. "Syllabus." Tyler v. United States, 281 U.S. 497 (1930), in 281 U.S. 497, page 281 U.S. 498. Original Sources. 22 Nov. 2024. http://originalsources.com/Document.aspx?DocID=NYA2ZF8ZRPUBN3E.
Harvard: U.S. Supreme Court, 'Syllabus' in Tyler v. United States, 281 U.S. 497 (1930). cited in 1930, 281 U.S. 497, pp.281 U.S. 498. Original Sources, retrieved 22 November 2024, from http://originalsources.com/Document.aspx?DocID=NYA2ZF8ZRPUBN3E.
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