annuity value of $1.00 at the age of 30 to be $14.8963. The income at the rate of 5% is $5,000 which multiplied by the annuity value of $1.00 at 30 years gives $74,481.50 as the value of the life estate and the subtraction shows $25,518.50 as the value of the remainder.

By the reference to the table of rates and exemptions in the abstract of the statute of Idaho (see appendix) we find that the widow and minor child each have an exemption of $10,000. As to the life estate the tax on the first $25,000 of the excess is 1% or $250, leaving $25,000 to be taxed at 1% or $375 and 14,481.50 to be taxed at 2% or $289.63, a total tax to the life tenant of $914.63.

As to the remainder of $25,518.50 the exemption of $10,000 leaves $15,518.50 taxable at 1% or $155.19 as the tax against the remainder.

C.

THE VALUE AND TAX IN TENNESSEE..

As to the $100,000 invested in Tennessee we find that this state uses the Carlisle table on the basis of 6% Table F. Referring to table F we find that an annuity of $1.00 is valued at $13.020; at 6% the annual income is $6,000, which multiplied by the present worth of an annual income of $1.00 gives $78,120 as the value of the life estate and by subtraction the remainder value is $21,880.

By reference to the table of rates and exemptions in the abstract of the Tennessee statute (see appendix), we find that the exemption to each is $5,000. The life tenant's interest less $5,000 is $73,120 of which $20,000 pays a tax at 1% or $200 and the balance $53,120 pays a tax of 14% or $664.00, a total of $864 as against the life tenant. The remainder, less the $5,000 exemption, pays a tax of 1% on $16,880 or $168.80.

d. THE TAX DUE THE STATE OF NEW YORK.

The value of the life estate in New York as we have seen by the first illustration is $226,263.75 and of the remainder $73,736.25.

As death occurred in January, 1917, the rates and exemptions prescribed by the statute of 1916 are in force. This gives the widow and child each an exemption of $5,000. The life estate subject to tax is valued at $221,263.75 and it pays these rates:

The remainder less the exemption is $69,736.25 on which the tax is $1,044.73.

The inheritance tax levied by the United States government took effect September 8, 1916, and the amendment of March 3, 1917, increased the rates by fifty per cent. The assumed testator died in January, 1917, and his estate is therefore taxable under the 1916 statute and not under the 1917 amendment.

The entire net estate is $300,000 and an exemption of $50,000 is allowed, making the taxable estate $250,000. The State taxes are not deducted by the ruling of the treasury department of Sept., 1917 — reversing its former rule. The net estate is therefore $250,000 taxed as follows:

The Federal Government, under the present statute does not concern itself with the apportionment of the

burden among the beneficiaries. The entire tax must be paid out of the residuary estate. In the present case it makes no difference, but if these were specific legatees in the supposed case they would escape payment of the tax altogether.

f. THE TOTAL TAX AND THE DISCOUNTS.

We now have the problem of the total tax and the discounts. The previous work shows the taxes as follows:

This total, however, may be somewhat reduced by the discounts allowed by the several statutes for the prompt payment of the tax.

By referring to the table of interest and discount of taxes or to the statutes in the appendix it will appear that Tennessee allows 5% discount if paid within three months; the other three states 5% discount if paid within six months, and the United States 5% per annum for the time payment anticipates one year. If these taxes are all paid immediately there will be a discount of 5% on all and a total saving of $757.36.

The total tax due the four states and the Federal

government less the possible discount for prompt payment is therefore $14,389.91.

These examples and illustrations should enable the average attorney to work out the more simple problems of inheritance taxation.

As to successive life estates and estates for joint lives the calculations require the use of other tables and higher mathematics and should be referred to an actuary or expert mathematician.

PART IV-THE PROPERTY

A. As to Situs.

1. Real Estate.

a. Not Taxable in Foreign Jurisdiction.
b. No Equitable Conversion.

c. Land Contracts.

d. Leases.

2. Tangibles.

3. Mortgages, Bonds and Commercial Paper.

a. Situs at Domicile of Owner.

b. Where the Land Lies.

c. Where Physically Present.

d. "Transient" or "Habitual" Presence.

4. Corporate Stock.

a. Of Domestic Corporations.

b. Foreign Corporations Owning Property Within the State. c. Foreign Corporations Not Owning Property Within the State.

d. Apportionment of Corporate Property.

e. Pledged Securities.

5. Other Choses in Action.

a. Bank Deposits.

b. Debts.

c. Life Insurance.

d. Seat in the Stock Exchange.

e. Interest in the Estate of Another.

f. Partnership Interest.

B. As to Value.

1. Where the Value at Death Cannot be Ascertained.

2. Real Estate.

3. Tangibles.

a. Pictures.

b. Furniture.

c. Jewelry.

4. Stocks.

a. Active Securities.

b. Inactive Securities.

c. Closely Held Stocks.

5. Bonds.