Shaughnessy v. Perlman

The question raised on this appeal is whether the Maryland inheritance tax on property passing in remainder to a taxable remainderman, upon the death of a taxable life tenant, is to be computed upon the value of such property as of the date of the death of the testatrix, or as of the date it vests in possession.

There is no dispute as to the facts. Claribel Cone, a resident of Baltimore City, died September 20, 1929. By the Thirteenth Item of her will, she left her art collection to her sister, Etta Cone, for life, giving her an unrestricted power of appointment over it by will or deed. By the…