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Guaranty Trust Co. v. Virginia, 305 U.S. 19 (1938)

Guaranty Trust Co. v. Virginia

No. 9

Argued October 11, 12, 1938

Decided November 7, 1938

305 U.S. 19


1. The question whether a state statute providing for taxation of trust income to the trustees when distribution by them is discretionary, and to the beneficiary when it is not, would operate to deny equal protection if income of a discretionary trust were to be taxed under it first to the trustee and again to the beneficiary, while income from ordinary trusts was taxed only once, does not arise in a case where there has been but one tax imposed under the statute -- the tax on the beneficiary -- and when there is no ground to suppose that the statute will be so construed and applied by the state authorities as to result in double taxation. P. 305 U. S. 23.

2. Virginia and New York both have laws taxing trust income to the trustee when distribution is discretionary, but to the beneficiary when it is not. Held, that taxation of a citizen and resident of Virginia upon income received there from a trust established and

Page 305 U. S. 20

administered in New York was not violative of the due process clause of the Fourteenth Amendment, although such income came from income of the trust which was taxed to the trustees by New York. P. 305 U. S. 23.

169 Va. 414; 193 S.E. 534, affirmed.

Certiorari, 303 U.S. 632, to review the affirmance of a judgment denying relief in an action to set aside income tax assessments, and to recover the taxes, theretofore paid under protest.

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