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action amount applied assessed assessor assets authority beneficiaries bonds capital cent choses in action City claim clause collected Commissioner Company Congress Constitution contemplation of death corporation County Court of Appeals debt decedent decision deduction defendant delivered the opinion determined direct tax distribution District domicile due process effect erty estate tax ex rel excise executor exemption fact federal Fourteenth Amendment gain gift gifts inter vivos Harv held Helvering imposed included income tax inheritance tax interest judgment jurisdiction Justice land legislature levied liability ment owner paid payment Pennsylvania personal property petitioner Phellis plaintiff plaintiff in error profits prop purpose question real estate reason received Revenue Act securities settlor shares situs Sixteenth Amendment Stat statute stockholder supra Supreme Court sustained tax law taxable taxation taxpayer tion transfer trust United valuation Yale L.J. York