Inheritance Taxes.—There is no denial of equal protection in prescribing different treatment for lineal relations, collateral kindred and unrelated persons, or in increasing the proportionate burden of the tax progressively as the amount of the benefit increases.1419 A tax on life estates where the remainder passes to lineal heirs is valid despite the exemption of life estates where the remainder passes to collateral heirs.1420 There is no arbitrary classification in taxing the transmission of property to a brother or sister, while exempting that to a son-in-law or daughter-in-law.1421 Vested and contingent remainders may be treated differently.1422 The exemption of property bequeathed to charitable or educational institutions may be limited to those within the State.1423 In computing the tax collectible from a nonresident decedent's property within the State, a State may apply the pertinent rates to the whole estate wherever located and take that proportion thereof which the property within the State bears to the total; the fact that a greater tax may result than would be assessed on an equal amount of property if owned by a resident, does not invalidate the result.1424
1418 Welch v. Henry, 305 U.S. 134 (1938).
1419 Magoun v. Illinois Trust & Savings Bank, 170 U.S. 283, 288, 300 (1898).
1420 Billings v. Illinois, 188 U.S. 97 (1903).
1421 Campbell v. California, 200 U.S. 87 (1906).
1422 Salomon v. State Tax Comm'n, 278 U.S. 484 (1929).
1423 Board of Educ. v. Illinois, 203 U.S. 553 (1906).
1424 Maxwell v. Bugbee, 250 U.S. 525 (1919).
Last modified: June 9, 2014