Central Union Trust Co. of New York v. Edwards

(after stating the facts as above). Admittedly the. statute created an excise or privilege tax, not one directly laid on property. Admittedly, also, the tax is to be measured by property, and it states the philosophy or fundamentals of this difference between the treasury and the taxpayer, to inquire, Whose property? That of the trust company, or that of its shareholders? If one is to pay a tax measured by property, it assuredly seems more consonant with philosophical jurisprudence to measure the same by the property-of the taxpayer, rather than by the possessions of another. But taxes are…