In re the Transfer Tax upon the Estate of Hecht

These appeals concern the constitutionality and interpretation of the amendments to section 230 of the Tax Law made by chapter 144 of the Laws of 1925. Prior to the enactment of that statute, under this section a contingent remainder was assessed for taxation at the highest rate possible on the happening of any contingencies and the tax was presently levied. By section 241 it had been provided that the State should retain and hold to the credit of the estate so much of the tax assessed upon such contingent remainders as represented the difference between the tax at the highest rate and the…