People Ex Rel. Bankers Trust Co. v. Graves

In the year 1924, Ephraim L. Corning died a resident of Connecticut. His will established trust funds for the benefit of designated individuals with remainders to others under certain contingencies. His estate included stocks and bonds of New York corporations and, pursuant to section 230 of the Tax Law (Cons. Laws, ch. 60), a tax was assessed in this State upon them, including a tax of $31,405.65 upon the contingent remainders at the highest rate possible under any contingency that might affect the vesting of those remainders. The tax was paid December 1, 1924. That assessment was made…