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mus encroachments have been made upon the by the will consisted of Federal, municipal, ancient maxim, and a rule has grown up in and corporation bonds, in custody of the modern times that legislatures may deal agents of the deceased in New York. It is with the personal as well as with the real the locality of the property within the ju. property of nonresidents within their juris- risdiction of the United States which subdiction, and that such property, while en- jeots it, if at all, to the legacy or succession joying the protection and benefits of the tax. local law, may be taxed for the expenses of It is an old and familiar rule of the En. the local government. These doctrines have glish courts, applicable to all forms of taxafound expression in a large number of cases tion, and particularly special taxes, that in this court. Green v. Van Buskirk , 5 the sovereign is bound to express its intenWall. 307, 18 L. ed. 599, 7 Wall. 139, 19 L. tion to tax in clear and unambiguous laned. 109; Hervey v. Rhode Island Locomo- guage, and that a liberal construction be tive Works, 93 U. S. 664, 23 L. ed. 2003; given to words of exception confining the Walworth v. Hurris, 129 U. S. 355, 32 L. ed. operation of duty (Warrington v. Furbor, 712, 9 Sup. Ct. Rep. 340; Security Trust Co. 8 East, 242, 247; Williams v. Sanger, 10 v. Dodd, 173 U. S. 624, 43 L. ed. 835, 19 East, 66, 69; Denn ex dem. Manifold v. Sup. Ct. Rep. 545, and cases there cited. Diamond, 4 Barn. & C. 243, 245; Tomkins

Recent cases in this court have affirmed v. Ashby, 6 Barn. & C. 541; Doe ex dem. very broadly the right of the legislature to Scruton v. Smith, 8 Bing. 146, 152; tax the local property of nonresidents, and Wroughton v. T'urtle, 11 Mees. & W. 561, particularly of corporations who are pur- 567; Gurr v. Scudds, 11 Exch. 190), though mitted by comity to do business within the the rule regarding exemptions from general state. Delaware Railroad Tax, 18 Wall. laws imposing taxes may be different. 206, sub nom. Minot v. Philadelphia, W. & Cooley, Taxn. 146; Re Enston, 113 N. Y. B. R. Co. 21 L. ed. 888; Erie R. Co. v. Penn- 174, 177, sub nom. People v. Sherwood, 3 L. sylvania, 21 Wall. 492, 22 L. ed. 595; West. R. A. 464, 21 N. E. 87. ern U. T'eleg. Co. v. Atty. Gen. 125 U. S. We have ourselves had repeated occasion 530, 31 L. ed. 790, 8 Sup. Ct. Rep. 961; to hold that the customs revenue laws Marye v. Baltimore & 0. R. Co. 127 U. S. should be liberally interpreted in favor of 117, 32 L. ed. 94, 8 Sup. ct Rep. 1037; the importer, and that the intent of ConPullman's Palace Car Co. v. Pennsylvania, gress to impose or increase a tax upon im141 U. S. 18, 35 L. ed. 613, 3 Inters. Com. ports should be expressed in clear and un. Rep. 535, 11 Sup. Ct. Rep. 876; Adams Exp. ambiguous language. Hartranft v. WiegCo. v. Ohio State Auditor, 166 U. S. 185, mann, 121 U. S. 609, 30 L. ed. 1012, 7 Sup. 41 L. ed. 965, 17 Sup. Ct. Rep. 604. The Ct. Rep. 1240; American Net & Túine Co. same principle has been applied not only to v. Worthington, 141 U. S. 468, 35 L. ed. tangible property but to credits and effects. 821, 12 Sup. Ct. Rep. 55; United States v. Tappan v. Al erchants' Nat. Bank, 19 Wall. Wigglesworth, 2 Story, 369, Fed. Cas. No. 490, 22 L. ed. 189; Savings & L. Soc. v. Mult- 16,690; Powers v. Barney, 5 Blatchf. 202, nomah County, 169 U. S. 421, 42 L. ed. Fed. Cas. No. 11,361. 803, 18 Sup. Ct. Rep. 392; New Orleans v. It is pertinent in this connection to exStempel, 175 U. s. 309, 44 L. ed. 174, 20 amine similar statutes passed in other counSup. Ct. Rep. 110; Bristol v. Washington tries and in the several states of this Union, County, 177 U. S. 133, 44 L. ed. 701, 20 and to inquire what construction is given Sup. Ct. Rep. 585.

to them. By the English tax legacy act of The question in each case is not of the 1796 a tax was imposed on every legacy power of the legislature to tax the personal "given by any will or testamentary instru. property of nonresidents, both tangible and ment to any person who shall die after the intangible, since that is well established passing of this act." In Atty. Gen. v. Cockboth in England and America (Mager vi erell (1814) 1 Price, 165, this was held by Grima, 8 How. 490, 12 L. ed. 1172), but of the court of exchequer to apply to a legacy its intent to do so by the particular act in bequeathed by a British subject residing in question. The inheritance-tax law of the the East Indies to persons living in EngUnited States above cited applies to prop- land, if the executor proved the will in Eng. erty“passing by will or by the intestate laws land, and paid the gacy there, though the of any state or territory.” As the property testator held his property in India, and rein this case did not pass under any will ex- sided and made his will and died there. The ecuted in any state or territory of the Unit- case was put upon the ground that the will ed States, or by the intestate laws of any was proved in England, that the executors such state or territory, the case is not with had received the property there, and that in the literalism of the act, unless we are the legatees resided there and were to be to use the word "state" in a sense broad paid there. But the case is further distinenough to include a foreign state or terri. guishable from the one under consideration in tory. As*matter of fact, the decedent was the fact that the testator was a British suba Španish subject, who had never resided ject and domiciled in a British possession, in the United States, had executed a will although the stress of the case was laid upat Paris in the Spanish language, pursu- on the residence of the legatees in England. ant to the laws of Spain, under which will Atty. Gen. v. Beatson (1819) 7 Price, 560, one third of his property passed to his son differs from the last one only in the fact and two thirds to the same person under the that the property bequeathed was in India, intestate laws of Spain. The property left and was remitted to England and paid to

889

names.

legatees residing in Scotland. But it was tween the legacy tax act and the succession held in Re Ewin (1830) 1 Comp. & J. duty act, which came into operation May 151, that foreign stocks, the property of a 19, 1853; and in Re Lovelace, 4 De G. & J. testator domiciled in England, were liable 340, it was said that the latter act applied to the legacy duty, although the stocks were to a succession inter vivos under a British transferable and the dividends were payable settlement to British property vested in in the foreign countries. In this case the British trustees, and falling under the julaw of the domicil was held to be control. risdiction of a British court, although the ling and the domicil to be the situs of the persons entitled were aliens domiciled personal property. The two cases from abroad. This case arose under an English Price were not cited.

marriage settlement made in England on In Jackson v. Forbes, 2 Cromp. & J. 382, the marriage of two English subjects, and a testator born in Scotland, who resided and affected English personalty only. In Waldied in India, leaving property there, but lop's Trust, 1 De G. J. & S. 658, a distingnone in England, left his property to his tion was drawn between the legacy act of four natural children. The property was George III. and the succession duty act, and collected by his executors, sent to England, a broader construction given to the latter. and invested in their own

The In Wallace v. Atty. Gen. L. R. 1 Ch. App. court held the property exempt from legacy 1, it was held that a succession duty was duties, apparently upon the ground that the f*not payable on legacies given by the will of property was administered by the executors a person domiciled in a foreign country, without necessarily invoking the aid of the The law was treated as settled by Thomcourt of chancery, although no reasons were son v. Advocate General, 12 Clark & F. 1, given in the opinion. Up to this time it had and the question discussed on principle in a been thought that, if the legacy were paid vigorous opinion. The converse of this case from assets administered in England, the is that of Atty. Gen. v. Napier, 6 Exch. 217, duty was payable. The two cases from in which a British-born subject died in InPrice were oited, but not discussed. This dia, though he had never acquired a domi. case was subsequently affirmed by the House cil there, and it was held that the whole of of Lords under the name of Atty. Gen. v. his property, though chiefly situate abroad, Jackson, 8 Bligh. N. R. 15. The case of was liable to a legacy duty. This case is Logan v. Fairlie, 1 Myl. & C. 59, was a simi- similar to that of Euin, 1 Cromp. & J. 151, lar case, and the legacy was held to be ex- above cited, though decided twenty years empt upon its authority.

later. See also Atty. Gen. v. Campbell, L. But in Arnold v. Arnold, 2 Myl. & C. 256, R. 5 H. L. 524; Lyall v. Lyall, L. R. 15 a similar case of a testator residing and Eq. 1. dying in India, leaving property there From this analysis of the English cases which was remitted to England and ad. it clearly appears that, under a general act ministered there, the legacy tax was held imposing a duty upon legacies, the law of not to be payable, and the question was re- the domicil of the testator controls, and if garded as finally settled by Atty. Gen. v. he be domiciled abroad, whether an alien or Jackson. The two cases from Price were a British subject, his legacies are exempt, overruled.

whether the property be in England at the Finally, in Thomson v. Advocate General, time of his death, or be subsequently re12 Clark & F. 1, a British-born subject died, mitted there by his executors for local ad. domiciled in a British colony. At the time ministration and distribution. of his death he was possessed of personal We proceed now to an examination of the property in Scotland. Probate of his will state decisions upon the same subject, was taken out in Scotland for the purpose which, with one or two exceptions, tend in of administering that property, and legacies the same direction. The Massachusetts were paid to legatees residing there. It collateral-inheritance law of 1891 imposee was held by the House of Lords that no leg. a tax upon "all property within the juris. acy duty was payable. The two cases from diction of the commonwealth, Price were flatly overruled, the other cases whether belonging to inhabitants of the comcited and discussed at length, and the doc-momoealth or not, and whether tangible or trine of domicil applied. This case must be intangible, which shall pass by will or by regarded as settling the law of England up- the laws of the commonwealth regulating on the subject.

intestate succession,” etc. In Callahan v. It will be observed in these cases that the Woodbridge, 171 Mass. 595, 51 N. E. 176, testator was a British subject, but in the it was held that under this act the succesCase of Bruce, 2 Cromp. & J. 436, the tession to property of nonresidents was ex tator was an American who lived and died pressly taxed as if the property belonged to abroad, having appointed an English exec. inhabitants of the commonwealth, and that utor and bequeathed property in England the language," which shall pass by will or to legatees residing there. The case is ex. by the laws of the commonwealth regulatactly in point, and the court had no diffi- ing intestate succession,' taken in connecculty in reaching the conclusion that the tion with the clauses immediately preceding property was not liable to legacy duty. it, applies to foreign wills, and to property

There are some later cases in England, that passes under the statute of this combut none that seem to qualify the rule laid monwealth which regulates the succession down in Thomson v. Advocate General. In to the property of a nonresident owner aftsome of themi a distinction is drawn be-'er his death." The testator in that case

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*587

lived in the state of New York, but the Maryland consisted of an undivided quarter property was within the jurisdiction of of the personal estate of the brother of the Massachusetts. The statute was held to testator, who died in Maryland. The act apply to property tangible or intangible. was held to apply, though the testator's We make no criticism of this case, which domicil was in California. The English was placed expressly upon the language of cases were cited and held to be distinguish. the statute.

able by reason of the peculiar language of The inheritance tax law of New York of the Maryland act. The language was evi. 1885 imposed a tax upon "all property which dently ambiguous, but the court having held shall pass by will or by the intestate laws that the words "being in this state” applied of this state, from any person who may die to the property, and not to the person, of seised or possessed of the same while being course its liability followed. A like cona resident of the state, or which property struction was given to the same words in shall be within this state, or any part of Com. v. Smith, 5 Pa. 142; Re Short, 16 Pa. such property

transferred by deed, 63. The case of Billings v. People, 189 I. grant, sale, or gift made or intended to take 472, 59 N. E. 798, is of no value, as the teseffect

after the death of the gran- tator, as well as his legatees, were domiciled tor," etc. (N. Y. Laws 1885, chap. 483, 8 in Illinois, and the question was as to the 1.] In Re Enston, 113 N. Y. 174 sub nom. liability of the widow's dower. People v. Sherwood, 3 L. R. A. 464, 21 N. The case of Alvany v. Powell, 55 N. C. E. 87, this was held not to apply to prop: (2 Jones Eq.) 51, is directly in point, and erty within the state which passed by will undoubtedly sustains the positions of the or intestacy from a nonresident decedent to gvernment in this case, The North Carocollateral relatives or strangers, legatees lina inheritance act imposed a tax upon "all domiciled in the state, and the latter clause, personal property or goods bequeathed to "or which property shall be within the strangers or collateral kindred, or which state,” was held to be limited to such as shall be distributed to or amongst the next was transferred by deed, grant, sale, or gift of kin, of any intestate, when such next of inter vivos. The act was amended in 1887 kin are collateral relations of such intes80 as to include "all property which shall tate.” The act was held to apply to property pass by will or by the intestate laws of this in North Carolina descending to a brother state, from any person who may die seised from an intestate domiciled in Canada. or possessed of the same while a resident of The court was satisfied that the true prin. this state, or if such decedent was not a ciple, both in regard to real and personal resident of this state at the time of his property, was the situs of the property. death, which property or any part thereof The English case of Thomson v. Advocate shall be within this state." [N. Y. Laws General, 12 Clark & F. 1, decided by the 1887. chap. 713, & 1.) And in Romaine's House of Lords, was considered at length, Case, 127 N. Y. 80, 12 L. R. A. 401, 27 N. E. and thus criticised: "No one can read the 759, it was held to apply to personal property opinion delivered before the Lords in the in New York, owned by a nonresident intes- case of Thomson v. Advocate General, which tate at the time of his death, which was is the case in which the principle of the habitually kept or invested by him there. domicil is finally settled, without being There can be but little doubt of the propri- struck with the fact that there is through. ety of this ruling. In Whiting's Case, 150 out a marked paucity of reasoning." Thea N. Y. 27, 34 L. R. A. 232, 44 N. E. 715, the North Carolina case was decided in 1854, same rule was extended to bonds of foreign and, so far as we*know, has not been fol.* as well as domestic corporations, and cer- lowed in any other state, and it is the only tificates of stock of domestic corporations one to which our attention has been called (but not of foreign), owned by a nonresi- that seems to be in point in favor of the dent decedent, but deposited by him in a construction contended for by the govern. safe deposit vault in New York. Bronson's Case, 150 N. Y. 1, 34 L. R. A. 238, 44 N. E. 707, and Houdayer's Case, 150 state courts, but they either involve ques.

There are a number of other cases in the N. Y. 37, 34 L. R. A. 235, 44 N. E. 718. tions of taxation under general laws imposThese cases seem rather to accentuate the ing taxes upon real and personal property, general principle that general statutes im- not being special inheritance taxes, or the posing taxes upon legacies do not apply to language of the particular statute is such the personal property of nonresident testators, and that a special inclusion of such is as to create little doubt as to the intention necessary to subject it to taxation.

of the legislature to tax or not to tax the The inheritance-tax law of Maryland sub particular inheritance in question. Small's jects to taxation all* property "passing from Estate, 151 Pa. 1, 25 Atl. 23, 28; Weaver any person who may die seised or possessed v. State, 110 Iowa, 328, 81 N. W. 603; thereof, being in this state," and it was held State ec rel. Taylor v. St. Louis County Ct. in State v. Dalrymple, 70' Md. 294, 3 L. R. 47 Mo. 594; Catlin v. Hull, 21 Vt. 152; A. 372, 17 Atl. 82, that the words "being in People v. Home Ins. Co. 29 Cal. 533; People this state" referred, not to the decedent ex rel. Hoyt v. New York City & County himself, but to his property. The testator Tax & A. Comrs. 23 N. Y. 224; People ea was a resident of California, and his prop-rel. Jefferson v. Gardner, 51 Barb. 352. In erty was also bequeathed to residents of the some jurisdictions a distinction has been same state. The property which was in made between tangible and intangiblo

See also ment.

889.

069.

property which does not arise in this case. "or the intestate laws of any state or terriOrcutt's Appeal, 97 Pa. 179.

tory.” We are clearly of opinion that they The tax in question in this case, not be are, and that the words "passing by will” ing upon the property itself, but upon the are limited to wills executed in "any state succession (United States v. Perkins, 163 or territory" under whose laws the property U. S. 625, 41 L. ed. 287, 16 Sup. Ct. Rep. would pass, if the owner had died intestate. 1073; Magoun v. Illinois Trust & Sav. Bank, The whole scheme of the act evidently con170 U. S. 283, 42 L. ed. 1037, 18 Sup. Ct. templates the application of the tax only to Rep. 594; Knowlton v. Moore, 178 U. S. 41, the property of a person domiciled in a state 44 L. ed. 969, 20 Sup. Ct. Rep. 747), laws or territory of the United States whose imposing general taxes upon real and per- property is transmitted under our laws. sonal property are not controlling, when ap- This is evident not only from the language plied to taxes upon the succession, when of § 29, above quoted, but from the provi. such succession takes place and is governed sion of § 30, *that every executor, etc., by the laws of a foreign country. The act. shall pay to the collector or deputy ual situs of the property in such cases cuts collector of the district of which the debut a small figure, while in the case of gen- ceased person was a resident the amount of eral taxes upon such property it is now con. the duty or tax assessed upon such legacy sidered determinative of the whole question. or distributive*share," etc. It would be dif..

The question involved in this case, how- ficult to find language more expressive of an ever, arose under the act of June 30, 1864 intent to confine the tax to persons domi[13 Stat. at L. 285, chap. 173), before Mr. ciled in this country. It need only be added Justice Gray of this court, while holding that while the words "state or territory" the circuit court for Massachusetts, in Unit. are used in treaties, and perhaps also in ed States v. Hunnewell, 13 Fed. 617. Sec- some acts of Congress regulating our intertion 124 of that act imposed a duty on lega- national relations, as including foreign cies or distributive shares arising from states, they are used in the Constitution personal property passing from any person and in ordinary acts of Congress as apply. possessed of such property, either by will, or ing only to states or territories of the Unitby the intestate laws of any state or terri. ed States. tory. The action was brought to recover the If, as in several of the states, the words tax upon American securities bequeathed by “passing by will or by the intestate laws of a French citizen domiciled in France to a son this state," or similar words, are connected who was also domiciled there. The will was with words declaring that the tax was inexecuted in conformity with the French law tended to be imposed upon the estates of and was* duly proved there, though a local persons domiciled abroad, the latter provi. executor was appointed by the probate sion is held to apply, and the words "passcourt in Boston to transfer to the legatee ing by will or the intestate laws of this the securities in question. It was held that state” are held to include the estates of $ 124 did not make the duty payable when persons domiciled abroad. Such is the case the person possessed of such property died in Illinois: Billings v. Illinois, 189 Ill. testate if it would not be payable if such 472, 59 N. E. 798; Massachusetts: Callahan person died intestate; and as if the deceased v. Woodbridge, 171 Mass. 595, 51 N. E. 176; had died intestate her son would not have Greves v. Shau, 173 Mass. 205, 53 N. E. taken a distributive share by the intestate 372; Maine: State v. Hamlin, 86 Me. 495, laws of any state or territory, his rights 25 L. R. A. 632, 30 Atl. 76; Ohio: Laws of were the same if he took by will. In other 1894, p. 166; Connecticut: Laws of 1889, p. words, that the words “either by will or by 106; Tennessee: State v. Alston, 94 Tenn. the intestate laws of any state or territory” | 674, 28 L. R. A. 178, 30 S. W. 750. But it must be construed together, and would ap- is hardly necessary to say that the conply only to wills executed within any state struction given to these statutes would or territory of the United States. The have no application to cases where words case is precisely in point.

expressly providing for the estates of nonWe regard this case as a correct exposi- residents are omitted. tion of the law. It is not necessary to rely To say that we recognize by comity the exclusively upon the English cases, or upon law of a foreign domicil as controlling the those in the state courts, which hold that a transmission or succession of personal propgeneral law imposing an inheritance tax erty because it thereby becomes our law upon property passing by will or descent (and the property therefore taxable), as is does not apply to intangible personal prop-indicated in some cases, notably in Alvany erty within the jurisdiction of the taxing v. Powell, 55 N. C. (2 Jones Eq.) 51, is power, but owned by persons domiciled misleading, and little more than a play upabroad, under the laws of which domicil the on words. When we speak of our laws we property passes, since the statute in ques- mean to be understood as referring to our tion here applies only to property passing own statutory laws, or the common law we “either by will or by the intestate laws of inherited from the mother country, and any state or territory.” Now, as the find when we apply the laws of a foreign domicil ing in this case is that the property passed we do so, not because they are our laws, but partly under a Spanish will and partly un- because upon principles of comity we recog. der the intestate laws of Spain, the only nize those laws as applicable to the partic question is whether the words "passing by ular case. But to speak of such foreign will” are limited by the subsequent words 'laws as thereby becoming "the intestate

*592

laws of any state or territory” wherein imposed by the war revenue act of June 18, they are enforced is practically to confound 1898. the whole distinction between the law of the situs and the law of the domicil. We do

[No. 295.) not*enforce the law of Spain in this case be cause it is our law, but because the practice Argued November 21, 1901. Decided March of all civilized nations is to recognize the

17, 1902. law of the domicil as governing the transmission and inheritance

of personal prop. U PON CERTIFICATE from the Circuit would follow if estates, situated possibly quit on a question as to the inheritance tax in half a dozen countries, were administered imposed by the war revenue act. Answered and distributed according to the laws of in the negative. each country in which any portion of such

See same case in circuit court, 104 Fed. estate happened to be located. We decline 947. to hold the tax involved in this case applicable to this estate because the words of the Statement by Mr. Justice Brown: statute do not require it, and because the This was also an action brought in the thing taxed, that is, the transmission of the circuit court for the southern district of property to the legatees or next of kin, New York by Ruckgaber, as executor of the takes place in a foreign country. It is true last will and testament of Louisa Augusta that Congress may, and in certain cases has Ripley-Pinède, against the collector of interseen fit to, adopt the laws of a particular nal revenue, to recover an inheritance tax state, and apply them wthin a territory, paid to the defendant upon certain personal as was done when Congress applied the laws property in the city of New York. of Oregon to Alaska (23 Stat. at L. 25, The material facts, as set forth in the chap. 53), and certain statutes of Nebraska certificate, are briefly as follows: to Oklahoma (26 Stat. at L. 87, chap. 182). The testatrix, Louisa Augusta RipleyThey thereby became the laws of those ter- Pinède, died at Zürich, Switzerland, on ritories as much as if enacted by a territo- September 25, 1898, being at that time a rial legislature, and were universally appli- nonresident of the United States, and havcable. But that result follows expressly ing, for at least eight years immediately from the statute, and not from the recogni- preceding her death, been domiciled in, and tion of the foreign law as applicable to a a permanent resident of, the Republic of particular case. Section 2694 of the New France. She left a will dated November 6, York Code [Civil Proc.] recognizes this dis (1890, which was made in New York and in tinction, in its requirement that “except conformity to the laws of that state, where where special provision is otherwise made the testatrix was then sojourning, whereby by law, the validity and effect of the testa- she bequeathed all her personal property in mentary disposition of any other (than the United States to her daughter, Carmelia real] property situated within the state, von Groll, who was then, and is now, also a and the ownership and disposition of such nonresident of the United States, domiciled property where it is not disposed of by will, in Germany. Said will was probated in the are regulated by the laws of the state or surrogate's court of Kings county, New country of which decedent was a resident York, on February 17, 1899, and letters tes. at the time of his death."

tamentary were thereupon issued to the deConceding it to be within the power of fendant in error, a resident of said county Congress to impose an inheritance tax upon and state, who alone qualified as executor. property in this country, no matter where At the time of her death the testatrix owned or transmitted, it has not done so in owned a claim in account current against this case, and the questions propounded by one Carl Goepel and one Max Ruckgaber, the Court of Appeals must be answered in Jr., constituting the firm of Schulz & Ruck the negative.

gaber, both of whom resided in the county

of Kings and state of New York. She was Mr. Justice White and Mr. Justice Mc- also the owner of a share of stock in the Kenna concurred in the result.

Tribune Association, a New York corporation. The testatrix was also the owner of bonds and coupons of divers American cor

porations hereinafter particularly described. (184 U. S. 593)

Said chose in action, stock, bonds, and cerFRANK R. MOORE

tificate constituted all the personal prop

erty of every kind in the United States of MAX RUCKGABER, Executor, etc. America referred to in the said will. The

value of the said property of the testatrix Inheritance tax--personal property of non- at the date of her death, September 25,

resident alien--will executed in United 1898, as fixed and determined by appraisers States.

duly appointed, was $105,670.70." On or

about the 15th day of June, 1899, upon the Personal property in the United States, passing written demand of the collector of internal under the will of a nonresident allen executed revenue for the first district of New York, In New York during a temporary sojourn and under protest, the executor did make there, is not subject to the inheritance tax and render in duplicate to the said collector

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