Cory v. Brown

Opinion

ROUSE, J.

The principal question presented by this appeal is whether section 13851 of the Revenue and Taxation Code is constitutional.1 That *888section provides for an unconditional exemption from inheritance taxation for intangible personal property owned by residents of the United States living outside of California. The exemption is extended to residents of foreign countries only on condition that the country of residence (1) impose a like tax, and (2) exempt residents of California from such tax. The question set before us for resolution is whether section 13851 denies nonresidents of…