Ingram v. State

The respondent contends that the state of Wisconsin has no jurisdiction to levy a gift tax on the transfer of 'the trust property in question. On that issue, the learned trial court held that the state has jurisdiction to levy a tax on gifts of intangible property such as are involved herein. However, the court held that the assessment was unlawful because if any gift was made to respondent by the trust indenture, it could not be a'gift of the entire estate and no assessment was made or attempted to be made on the basis of the value of the alleged gift. The court further held that no gift…