Tax Commission v. Corwin

Are these notes, under the above circumstances, subject to a succession tax?

The determination of this question requires a construction of 5331 and 5332 GC. These sections of the Code have for their basis the constitutional provision found in Article 12 of Section 7 of the Ohio Constitution to the effect that “Laws may be passed providing for a taxation of the right to receive or to succeed to estates.”

As above stated, there is no dispute but that Charles Morgan Wood, a resident of the State of Massachusetts, died testate owning the notes in question and that they were in the physical…