In re the Estate of Rueff

Delehanty, S.

Appeal is taken from the pro forma order of this court which fixed an estate tax on the basis of the report of the appraiser. The appeal attacks the constitutionality of section 249-p of article 10-C of the Tax Law which became effective September 1, 1930. Deceased died August 31, 1931, a resident of the State of New Jersey. In the schedules upon which the appraiser acted there were listed as property owned by deceased in her lifetime various items of intangible personal property, the situs of which in law was outside this State. The schedules listed real property and tangible…