State v. First Wisconsin Trust Co.

We are of opinion that the bequest to Dr. Heuss is not exempted from the Wisconsin inheritance tax, either by our statutes or by treaty. Therefore, notwithstanding its laudable purpose, we must hold the bequest taxable, and reverse the contrary judgment of the county court.

We shall consider first the pertinent Wisconsin statutes, and then the various treaties claimed by respondent to prohibit taxation of the transfer by this state.

1. Wisconsin statutes do not exempt the bequest.

The pertinent provisions are subs. (1) and (3) of sec. 72.04, Stats.

Sub. (1) defines the general exemption…