Estate of Heckert v. State Board of Equalization

THOMAS, Justice.

The issue posed is the authority of the State of Wyoming to impose a transfer tax on the Wyoming estate of a decedent when the entire Wyoming estate is deducted from the federal gross estate in determining the federal taxable estate. The Wyoming Department of Revenue (the Department) imposed a transfer tax upon the Estate of Barbara K. Heckert (the Estate) in the amount of $30,283.95. That figure was computed by applying to the maximum federal estate tax credit for state inheritance or transfer taxes a ratio derived from the portion of the gross estate situate in Wyoming as…