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In the case of Leary v. United States (1911), the U.S Supreme Court dealt with a dispute over inheritance tax. The decedent, Timothy Leary, was an American citizen who had been living in Paris for several years before his death and left behind considerable property both in France and America. His executrix argued that only the property located within the United States should be subject to federal estate taxes while the government contended that all of Mr. Leary's worldwide assets were taxable under U.S law. The court ruled in favor of Mrs. Leary, holding that only those properties physically situated within national boundaries could be taxed by Congress under its constitutional authority to levy direct taxes "within" United States territory; therefore, it excluded overseas assets from being subjected to US taxation laws unless specifically stated otherwise by legislation or treaty agreements between countries involved.
The dissenting opinion in the case of Leary v. United States, 1911 was not recorded or is unavailable.