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Taxation-Procedural Devices For Preventing Multiple Taxation Of Intangibles Based On Domicile - Original Suit By Way Of Interpleader Before Supreme Court, Edmund O'Hare

Michigan Law Review

The famous Dorrance litigation raised very sharply the problem of avoiding multiple inheritance taxes based upon conflicting claims of domicile. Up to that time it was thought that the right of a state to levy an inheritance tax upon intangible personal property owned by a nonresident decedent had been effectively denied by Farmers Loan & Trust Co. v. Minnesota, Baldwin v. Missouri, and First National Bank of Boston v. Maine. But the Dorrance cases resulted in the collection of huge inheritance taxes by Pennsylvania and New Jersey, both states grounding their assessments upon the assertion that Dr. Dorrance …