Sage's Executors v. Commonwealth

*258Opinion op the Court by

Judge Clarke —

-Reversing’.

Mrs. Margaret Olivia Sage, the widow of Russell Sage, died testate on November 4, 1918, a resident of New York City. By her will, after making certain bequests to her relatives, she gave the residue of her large estate to various hospitals, educational institutions, churches and charitable organizations, none of which is located, or required to expend the money left it within this state.

By this action, the Commonwealth sought to collect an inheritance tax upon the interests devised to these nonresident benevolent institutions in 3,500 shares of…