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DISTRICT OF COLUMBIA v. CHASE MANHATTAN

No. 95-TX-1599.

689 A.2d 539 (1997)

DISTRICT OF COLUMBIA, Appellant, v. The CHASE MANHATTAN BANK, Appellee.

District of Columbia Court of Appeals.

Decided January 30, 1997.

Attorney(s) appearing for the Case

Lutz Alexander Prager, Assistant Deputy Corporation Counsel, with whom Charles F.C. Ruff, Corporation Counsel, and Charles L. Reischel, Deputy Corporation Counsel, were on the brief, for appellant.

John J. McAvoy, with whom Anne D. Smith and Ellen S. Moore were on the brief, Washington, for appellee.

Before FERREN, FARRELL and REID, Associate Judges.

FERREN, Associate Judge:

This case presents an issue of first impression in this court: can the District of Columbia, consistent with the Due Process Clause, tax the annual net income of a testamentary trust created by the will of an individual who died while domiciled in the District, when the trustee, trust assets, and trust beneficiaries are all presently located outside the District. We hold that the Due Process Clause does not prevent the District from imposing...

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