Landmark First National Bank of Fort Lauderdale v. Commissioner of Corporations & Taxation

The sole question to be determined on this appeal is whether Massachusetts real estate standing in the name of a nonresident decedent at the time of his death but which is subject to an executory agreement of purchase and sale is subject to taxation here under the provisions of the third paragraph of G. L. c. 65A, § 1. The linchpin of the taxpayer’s argument against the application of § 1 is the claimed applicability of the doctrine of equitable conversion. See Baker v. Commissioner of Corps. & Taxn., 253 Mass. 130, 134 (1925). See generally 1 *903Pomeroy, Equity Jurisprudence § 161 (4th ed.…