In re the Estate of Gould

Foley, S.

The executor has appealed on four separate grounds from the order fixing the transfer tax. Mrs. Gould died on November 13, 1921, a resident of Lakewood, N. J. Her will was admitted to probate in that state. She left a total estate of approximately $2,000,000. At the time of her death she was possessed of jewelry, household furnishings and personal effects worth about $900,000, which were located in the state of New York.

The first ground of appeal involves the question as to whether the jewelry and personal effects were taxable under the provisions of section 220, subdivision 2, of…