State Tax Comm'n of Utah v. Aldrich

The sole question presented by this case is whether the State of Utah is precluded by the Fourteenth Amendment from imposing a tax upon a transfer by death of shares of stock in a Utah corporation, forming part of the estate of a decedent who, at the time of his death, was domiciled in the State of New York and held there the certificates representing those shares.

In 1940, Edward S. Harkness died testate, being at that time domiciled in New York. His estate was probated *175in New York, where respondents were appointed executors. Respondents were also appointed administrators with the will…