Wheeler v. Sohmer
Supreme Court of the United States
ERROR TO THE SURROGATES’ COURT OF NEW YORK COUNTY, STATE OF NEW YORK. The facts, which involve the power of a State to tax promissory notes located in the. State although neither the owner nor the maker are residents thereof, are stated in the opinion.
1Opinion of the CourtJustice Holmes
This proceeding began with a petition by an executor, actitig under ancillary letters, for the appointment of an appraiser to determine the amount, if any, of the transfer tax due from the estate of the deceased testator, Charles C. Tiffany. Tiffany was not a resident of New York at the time of his death but left in a safe deposit box in New York four promissory notes made by Pottinger, a resident of Chicago, secured by mortgages of Chicago land to Illinois trustees, and promissory notes of the Southern Railway Company, a Virginia corporation. The appraiser held these notes taxable under the…
2Cases cited11 opinions
- Louisville & Nashville Railroad v. Barber Asphalt Paving Co.Supreme Court of the United States · 1905
- New Orleans v. StempelSupreme Court of the United States · 1899
- Bristol v. Washington CountySupreme Court of the United States · 1900
- Metropolitan Life Insurance v. City of New OrleansSupreme Court of the United States · 1907
- Wyman v. HalsteadSupreme Court of the United States · 1884
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3Cited by56 opinions
- Hanson v. DencklaSupreme Court of the United States · 1958
- Miller Brothers Co. v. MarylandSupreme Court of the United States · 1954
- Baldwin v. MissouriSupreme Court of the United States · 1930
- Safe Deposit & Trust Co. of Baltimore v. VirginiaSupreme Court of the United States · 1929
- Fidelity & Columbia Trust Co. v. City of LouisvilleSupreme Court of the United States · 1917
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