In re the transfer inheritance tax upon the estate of Dellinger

Buchanan, Vice-Ordinary.

The executor of the estate of Charles E. Dellinger, deceased, appeals from the so-called transfer inheritance tax assessed against that estate hy the comptroller. Appellant’s testator *410died March 20th, 1922, a non-resident of New Jersey, but having amongst his personal property certain stocks of New Jersey corporations, the transfer whereof is made taxable under our statute. P. L. 1909, p. 325, and subsequent amendments.

Admittedly the estate is subject to tax under the so-called “ratio clause” of the act, the last paragraph of section 12, which read as follows:

“A tax…