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City Bank Farmers Trust Co. v. Schnader, 291 U.S. 24 (1934)

City Bank Farmers Trust Co. v. Schnader

No. 84

Argued November 9, 1933

Decided January 8, 1934

291 U.S. 24


1. Where the state law permits an action at law for recovery of a tax paid under protest, the taxpayer may pursue the same remedy in the federal court if the requisite diversity of citizenship and amount in controversy are present. P. 291 U. S. 28.

2. Existence of a statutory remedy to test the validity of a tax appraisal by appeal to a particular state court, in which the party opposed to the taxpayer will be the state itself, will not affect the equity jurisdiction of the federal court to enjoin, since such a proceeding, even if regarded as an action at law, would be confined to the state court and would not be cognizable by the federal court, either originally or by removal. P. 291 U. S. 29.

3. A proceeding in a state court, on appeal from a tax appraisal, wherein the court has jurisdiction to determine not only the valuation, but also the validity of the tax, and which is tried as a case between the taxpayer and the state as adversary parties, and results in a final judgment appealable to a higher court, is to be classified as a judicial, rather than an administrative, proceeding. P. 291 U. S. 29.

4. To such a proceeding the principle that administrative remedies under state laws must be exhausted before an injunction against state officers is sought in the federal courts on constitutional grounds does not apply. P. 291 U. S. 34.

5. A bill to enjoin the imposition and collection of a state inheritance tax as beyond the constitutional power of the state held not premature, although the assessment had not yet been completed, it appearing clearly by the allegations of the bill that the defendant state taxing officials believed the tax valid and would proceed to impose it if not restrained. P. 291 U. S. 34.


Appeal from a decree of the District Court, of three judges, dismissing a bill to enjoin the Attorney General and the Secretary of Revenue of the Commonwealth of

Page 291 U. S. 25

Pennsylvania from imposing and collecting an inheritance tax on personal property left by a New York decedent, which, as the plaintiff executor averred, had no taxable situs in the Commonwealth.

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