In Re Miller

This is an appeal by the executrix and residuary legatee of Ralph E. Miller, deceased, from the transfer inheritance tax assessed against decedent's estate by the comptroller. Decedent was a non-resident of New Jersey, but had stock in New Jersey corporations, so that a tax was assessable under section 1, subsection 3 of our statute, and was computed in accordance with the so-called "ratio clause" in section 12 of the act.

In computing the tax the comptroller included as taxable transfers certain gifts made by decedent to his wife during a period of some five years prior to his death, and…