CORY v. WHITE

No. 80-1556.

457 U.S. 85 (1982)

CORY, CONTROLLER OF CALIFORNIA, ET AL. v. WHITE, ATTORNEY GENERAL OF TEXAS, ET AL.

Supreme Court of United States.

Decided June 14, 1982.


Attorney(s) appearing for the Case

Jerome B. Falk, Jr., argued the cause for petitioners. With him on the briefs were Martin R. Glick, Steven L. Mayer, Paul J. Van Osselaer, and Myron Siedorf.

O. Clayton Lilienstern argued the cause for respondents Lummis et al. With him on the brief were Patricia A. Stevenson, R. James George, Jr., John M. Harmon, and James William Moore. Rick Harrison argued the cause for respondents White et al. With him on the brief were Mark White, Attorney General of Texas, pro se, Gilbert J. Bernal, Jr., Assistant Attorney General, and David Deaderick.


JUSTICE WHITE delivered the opinion of the Court.

In this case, both Texas and California assert the right to levy state death taxes on the estate of Howard Hughes. The laws of each State impose an inheritance tax on the real and tangible personal property located within its borders, and upon the intangible personalty, wherever, situated, of a person domiciled in the State at the time of death. Under the laws of Texas and California, an individual has but one domicile...

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