Tax Comm. v. Clark, Exrx.

CUSHING, J.. Jesse Clark died Sept. 25, 1921 owning 8,567 shares of capital stock in the Union Central Life Insurance Co. The par value of the stock was $20 a share.

The Probate Court, acting under the inheritance tax statutes, directed the Auditor to appraise the property at its actual market value; and the Auditor found its value to be $25 per share. The Probate Court appraised the property de novo and fixed its value at $40 per share.

The Hamilton Common Pleas, on appeal, found the value to be $30 a share, on the theory that the payment of cash dividends on the stock was the basis of its…