Cases On Taxation

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209, 305, and cases there collected. United States v. St.
Paul, Minneapolis & Manitoba Eailway, 247 U. S. 310, 318. The design of "the framers of the act of 1916 to establish an estate tax as distinguished from a legacy or distribution tax is manifested by the report of the committee on ways and means of the national House of Eepresentatives, to which the revenue bill had been referred.
In that report made on July 5, 1916 (Report No. 923, 64th Con- gress, 1st Session), page 5, under the heading
... "Estate Tax," are found these words : " Thirty States have laws imposing inheritance or share taxes both upon direct and collateral heirs. Twelve other States have laws imposing inheritance taxes upon collateral heirs.
Your committee deemed it advisable to recommend a federal estate tax upon the transfer of the net estate rather than upon the shares passing to heirs and distributees or divisees and legatees. The federal estate tax recommended forms a well-balanced system of inheritance taxation as between the Federal Government and the various States, and the same can be readily administered with less conflict than a tax based upon the shares." An estate tax as distinguished from a legacy or succession tax is well recognized.


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