In re the Transfer Tax upon the Estate of Norton

Fowler, S.—

This is a proceeding certified to the surrogate under the Transfer Tax Law in order that he may determine the last legal residence of Edwin Norton, deceased. The State Comptroller contends that the decedent died a resident of this State, while the executors contend that he died a resident of the island of Bermuda, British territory. Under our Tax Law, if the decedent at the time of his death was a resident of -this State, all his personal property, wherever situated, would be subject to the transfer tax of this State, while if he died a resident of Bermuda the only part of his…