Greenough et al., Trustees, v. Tax Assessors of Newport et al. (331 U.S. 486)
U.S. Supreme Court · decided June 9, 1947 · Supreme Court Database (Spaeth)
- Citation
- 331 U.S. 486 · 67 S. Ct. 1400
- Docket
- No. 461
- Argued
- March 7, 1947
- Decided
- June 9, 1947
- Term
- October Term 1946
- Vote
- 5–4
- Majority author
- Justice Reed
- Issue area
- Economic Activity
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Liberal
How the Justices voted
- Majority
- Justice Burton, Justice Douglas, Justice Frankfurter (wrote a concurrence), Justice Reed (wrote), Justice Black
- Dissenting
- Chief Justice Vinson, Justice R. H. Jackson (wrote), Justice Rutledge (wrote), Justice Murphy
Opinion excerpt
Mr. Justice Reed delivered the opinion of the Court. Appellants are testamentary trustees of George H. Warren, who died a resident of New York. His will was duly probated in that state and letters testamentary issued to appellants as executors. A duly authenticated copy of said will was filed and recorded in Rhode Island and there letters testamentary were also issued. Letters of trusteeship were granted to appellants by a surrogate’s court in New York. None were needed or asked for or granted by Rhode Island. At all times pertinent to this appeal, appellants, as trustees under the will, held intangible personalty for the benefit of Constance W. Warren for her life and then to certain as yet undetermined future beneficiaries. The evidences of the intangible property in the estate of George H. Warren and in the trust in question were at all times in New York. The life beneficiary and one of the trustees are residents of New York. The other trustee resides in Rhode Island. During the period in question, he did not, however, exercise his powers, as trustee, in Rhode Island. A personal property tax of $50 was assessed by the City of Newport, Rhode Island, against the resident trustee upon one-half of the value of the corpus of the trust. The applicable assessment statute for ad valorem taxes appears in the margin. At the time of this assessment, the property consisted of 500…
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