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NICKEL v. COLE

Nos. 268, 269.

256 U.S. 222 (1921)

NICKEL ET AL., AS TRUSTEES, & c., ET AL. v. COLE, AS STATE CONTROLLER OF THE STATE OF NEVADA. NICKEL ET AL., AS TRUSTEES, & c., ET AL. v. STATE OF NEVADA.

Supreme Court of United States.

Decided April 25, 1921.

Attorney(s) appearing for the Case

Mr. Edward F. Treadwell, with whom Mr. Azro E. Cheney was on the brief, for plaintiffs in error.

Mr. Leonard B. Fowler, Attorney General of the State of Nevada, with whom Mr. Robert Richards and Mr. Wm. C. Prentiss were on the brief, for defendants in error.

Mr. Garret W. McEnerney, by leave of court, filed a brief as amicus curiae.

MR. JUSTICE HOLMES delivered the opinion of the court.

The first of these suits was brought by the Controller of Nevada to collect a transfer tax alleged to be due under a statute of Nevada approved on March 26, 1913, to take effect thirty days from that date. Nevada Stats. of 1913, c. 266, p. 411. The second suit was brought to quiet title to the shares of stock in respect of which the tax was assessed — to establish that there was no lien upon or claim against...

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