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Fernandez Vs. Wiener

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  • US Supreme Court
  • Dec 10, 1945

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  17. U.S. 340 (1945) U.S. Supreme Court Fernandez v. Wiener
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  18. U.S. 340 (1945) Fernandez v. Wiener
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  19. a). See Detroit Bank v. United
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  20. the states to determine how the tax burden shall be distributed among those who share in the taxed estate. See Riggs v. Del
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  21. governing the interests of the spouses in community property states. Page 326 U. S. 348 See, e.g., Moffitt v. Kelly
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  22. U. S. 44 . Counsel for appellees concede that the opinion in Bender v. Pfaff
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  23. power to lay and collect an excise. Congress has a wide latitude in the selection of objects of taxation, Brushaber v. Union
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  24. Steward Machine Co. v. Davis
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  25. share of the tax burdens and similar or like property passing to the same class of beneficiaries which has not. Watson v. State
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  26. It is true that the estate tax as originally devised and constitutionally supported was a tax upon transfers. Knowlton v. Moore
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  27. YMCA v. Davis
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  28. by death, it may as readily be the subject of the federal tax as the transfer of the property at death. See Bromley v. McCaughn
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  29. shifting from one to another of any power or privilege incidental to the ownership or enjoyment of property. Bromley v. McCaughn
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  30. Nashville, C. & St.L. Ry. v. Wallace
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  31. Henneford v. Silas
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  32. may constitutionally Page 326 U. S. 353 be taxed, obviously it is competent to tax the use of it, Hylton v. United
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  33. Billings v. United
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  34. States, 232 U. S. 261 , or the sale of it, Nicol v. Ames
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  35. Thomas v. United
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  36. States, 192 U. S. 363 , or the gift of it, Bromley v. McCaughn
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  37. of a power of disposition of property where other important indicia of ownership are lacking. Saltonstall v. Saltonstall
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  38. Chase National Bank v. United
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  39. Graves v. Schmidlapp
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  40. there is any want of constitutional power to tax the receipt of it, whether as the result of inheritance, Stebbins v. Riley
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  41. property so Page 326 U. S. 354 held. We upheld a like tax when applied to tenancies by the entirety in Tyler v. United
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  42. Third National Bank & Trust Co. v. White
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  43. U.S. 577, and to property held in joint tenancy in United States v. Jacobs
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  44. and Dimock v. Corwin
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  45. transfer, or on any event which antedated the death of one of the joint owners. Instead, as we said in Whitney v. State
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  46. We pointed out in Tyler v. United
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  47. the property in the gross estate which forms the primary basis for the measurement of the tax. And, in United States v. Jacobs
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  48. U. S. 56 , 290 U. S. 58 . Compare Saltonstall v. Saltonstall
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  49. a power to dispose of property, created before the enactment of the tax statute, does not offend due process, Reinecke v. Northern
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  50. does a tax upon the receipt of income which was earned and due before the enactment of the taxing statute. Brushaber v. Union
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