blodgett
holden
argued
october
decided
november
modified
mark
norris
grand
rapids
plaintiff
alfred
wheat
washington
defendant
per
curiam
equal
division
opinion
among
eight
justices
heard
considered
matter
renders
impossible
categorically
answer
certified
question
two
questions
think
essential
statements
views
justices
enough
show
tax
exacted
blodgett
sustained
sections
revenue
act
usca
comp
enable
circuit
appeals
readily
reach
proper
decision
cause
remanded
appropriate
action
justice
mcreynolds
circuit
appeals
sixth
circuit
certified
three
questions
asked
instructions
respect
title
section
necessary
answer
one
follows
provisions
sections
revenue
act
stat
usca
comp
unconstitutional
far
impose
levy
tax
upon
transfers
property
gifts
inter
vivos
made
contemplation
death
made
prior
june
date
act
approved
direct
tax
unapportioned
takes
property
without
due
process
public
use
without
compensation
violation
fifth
amendment
revenue
act
approved
june
provides
calendar
year
calendar
year
thereafter
tax
equal
sum
following
hereby
imposed
upon
transfer
resident
gift
calendar
year
property
wherever
situated
whether
made
directly
indirectly
upon
transfer
nonresident
gift
calendar
year
property
situated
within
whether
made
directly
indirectly
per
centum
amount
taxable
gifts
excess
etc
gift
made
property
fair
market
value
thereof
date
gift
shall
considered
amount
gift
property
sold
exchanged
less
fair
consideration
money
money
worth
amount
fair
market
value
property
exceeded
consideration
received
shall
purpose
tax
imposed
section
deemed
gift
shall
included
computing
amount
gifts
made
calendar
year
section
allows
certain
deductions
donations
charitable
purposes
etc
section
unimportant
person
within
year
calendar
year
thereafter
makes
gift
gifts
excess
deductions
allowed
section
shall
day
march
file
collector
return
oath
duplicate
listing
setting
forth
therein
gifts
contributions
made
calendar
year
tax
imposed
section
shall
paid
donor
day
march
shall
assessed
collected
paid
manner
subject
far
applicable
provisions
law
tax
imposed
section
act
february
stat
usca
section
revenue
act
amended
read
follows
sec
calendar
year
calendar
year
tax
equal
sum
following
hereby
imposed
upon
transfer
resident
gift
calendar
year
property
wherever
situated
whether
made
directly
indirectly
upon
transfer
nonresident
gift
calendar
year
property
situated
within
whether
made
directly
indirectly
per
centum
amount
taxable
gifts
excess
succeeding
percentages
less
higher
specified
act
subdivision
section
shall
take
effect
june
calendar
year
prior
june
plaintiff
blodgett
resident
transferred
gifts
inter
vivos
contemplation
death
property
valued
june
made
gifts
valued
collector
exacted
tax
prescribed
act
amended
transfers
suit
seeks
recovery
sum
paid
claim
taxing
act
applicable
circumstances
stated
conflicts
fifth
amendment
argument
counsel
blodgett
affirmed
transfers
prior
june
really
made
month
january
accuracy
statement
questioned
circumstances
treat
affirmation
part
recital
facts
brief
behalf
collector
sets
legislative
history
gift
tax
provisions
revenue
act
shows
presented
consideration
congress
prior
february
year
must
therefore
determine
whether
congress
power
impose
charge
upon
donor
gifts
fully
consummated
provisions
came
nichols
coolidge
may
pointed
statute
purporting
lay
tax
may
arbitrary
capricious
enforcement
amount
deprivation
property
without
due
process
law
within
inhibition
fifth
amendment
gifts
blodgett
made
january
think
challenged
enactment
arbitrary
reason
invalid
seems
wholly
unreasonable
one
entire
good
faith
without
slightest
premonition
consequence
made
absolute
disposition
property
gifts
thereafter
required
pay
charge
determination
cause
require
us
consider
objections
statute
advanced
unnecessary
express
opinion
concerning
validity
statute
transfers
subsequent
june
gifts
within
exemption
granted
far
revenue
act
undertakes
impose
tax
gifts
made
january
arbitrary
invalid
due
process
clause
fifth
amendment
chief
justice
justice
van
devanter
justice
butler
concur
opinion
justice
holmes
although
research
shown
practice
established
futility
charge
usurpation
undertook
declare
act
congress
unconstitutional
suppose
agree
gravest
delicate
duty
called
perform
upon
among
considerations
rule
settled
two
possible
interpretations
statute
one
unconstitutional
valid
plain
duty
adopt
save
act
even
avoid
serious
doubt
rule
delaware
hudson
standard
brewery
texas
eastern
texas
bratton
chandler
panama
johnson
words
strained
need
strained
order
avoid
doubt
jin
fuey
moy
different
sphere
embodying
general
attitude
construction
see
goelet
revenue
act
june
stat
tax
laid
gifts
calendar
year
calendar
year
thereafter
code
words
calendar
year
title
latter
phrase
brings
think
obvious
without
aid
purpose
general
one
indicate
periods
regarded
distinguished
fiscal
years
necessarily
run
counter
usual
understanding
statutes
direct
future
past
transactions
reynolds
mcarthur
pet
ed
shwab
doyle
lewellyn
frick
statute
passed
well
recognized
congress
power
tax
past
gifts
think
trouble
reading
act
meant
operate
date
tax
gifts
thereafter
made
right
read
way
revenue
act
act
february
stat
act
amended
rates
taxation
reduced
provided
section
shall
take
effect
june
date
earlier
act
passed
reasonable
interpretation
reduction
tax
operate
alike
gifts
date
taking
statutes
account
principles
construction
referred
think
tolerably
plain
act
read
referring
transactions
taking
place
passed
disregard
rule
impose
unexpected
liability
known
might
induced
concerned
avoid
use
money
ways
lewellyn
frick
ed
general
question
whether
power
tax
gifts
express
opinion
agree
result
plaintiff
entitled
recover
taxes
paid
respect
gifts
made
statute
went
effect
justice
brandeis
justice
sanford
justice
stone
concur
opinion