SALOMON v. STATE TAX COMMISSION

Nos. 79 and 80.

278 U.S. 484 (1929)

SALOMON ET AL. v. STATE TAX COMMISSION OF NEW YORK. SIMONSON ET AL. v. SAME.

Supreme Court of United States.

Decided February 18, 1929.


Attorney(s) appearing for the Case

Mr. Charles Angulo, with whom Mr. Edmund O. Austin was on the brief, for plaintiffs in error in No. 79.

Mr. Abraham L. Gutman, with whom Mr. Wm. V. Goldberg was on the brief, for plaintiffs in error in No. 80.

Mr. Seth T. Cole for defendants in error.


Mr. JUSTICE BRANDEIS delivered the opinion of the Court.

These cases, which were argued together, present the question whether the provision in the New York Transfer Law for taxing the transfer of contingent remainders violates the due process clause or the equal protection clause of the Fourteenth Amendment. That statute imposes a graduated succession tax. On the transfer of life estates and vested remainders the tax is measured by their respective values as of the...

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