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Taxation-Jurisdiction To Tax Intangibles-Business Situs

Michigan Law Review

Decedent died domiciled in Illinois, owning the majority of stock in a South Carolina corporation, and a chose in action for a large sum owed him by the corporation, partly on open account, and partly for dividends declared but unpaid. The executors objected to the inclusion of the chose in an assessment under the South Carolina inheritance tax law, but the South Carolina court refused relief, basing jurisdiction to tax the transfer of the indebtedness, in part, on the ground that this property had acquired a business situs in South Carolina. On certiorari, this decision was reversed by the United …