Guaranty Trust Co. v. Blodgett, 287 U.S. 509 (1933)

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Guaranty Trust Co. v. Blodgett

No. 217

Argued December 15, 1932
Decided January 9, 1933
287 U.S. 509

APPEAL FROM THE SUPERIOR COURT OF

FAIRFIELD COUNTY, CONNECTICUT

Syllabus

1. Where it is claimed that a state statute imposing a tax has been applied by the state supreme court to an earlier contract in violation of the contract impairment clause of the Constitution, the opinion of that court definitely sustaining the tax on another statute antedating the contract must be accepted in the absence of convincing reasons to the contrary. P. 512.

2. The contract clause not being involved, a construction placed upon a state statute by the state supreme court binds this Court as fully as if expressed in the statute itself in specific words. P. 513.

3. Where property is conveyed irrevocably in trust to pay the income to the grantor during life, and thereafter to another beneficiary, the shifting of possession or enjoyment on the grantor’s death is an event "generated" by the death upon which the State constitutionally may impose a succession tax. P. 513.

114 Conn. 207, 158 Atl. 245, affirmed.

Appeal from a Judgment entered in the Superior Court of Connecticut on advice sent down from the Supreme Court of Errors in response to questions of law reserved for its decision. The case first came into the Superior Court by appeal of the Tax Commissioner from a decree of the Probate Court for the District of Greenwich holding the succession in question nontaxable.