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Lindgren, Administrator, v. United States Et Al.

• 1929 • 281 U.S. 38 • Hughes Court
In the case of Lindgren, Administrator v. United States et al., 1929, the U.S Supreme Court ruled on a dispute over inheritance tax. The plaintiff was the administrator of an estate that included shares in a corporation which had been transferred to him by non-resident aliens who were not citizens of America and did not live there at any point during their lives. The government imposed taxes on these shares as if they were part of an American citizen's estate, but Lindgren argued this was...Open Case
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Chief Hughes Court
Term: 1929
Docket: 25
281 U.S. 38
50 S. Ct. 207
74 L. Ed. 686
1930 U.S. LEXIS 715
Argued: Oct 25, 1929

Lindgren, Administrator, v. United States Et Al.

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Opinion Summary
AI Abstract

In the case of Lindgren, Administrator v. United States et al., 1929, the U.S Supreme Court ruled on a dispute over inheritance tax. The plaintiff was the administrator of an estate that included shares in a corporation which had been transferred to him by non-resident aliens who were not citizens of America and did not live there at any point during their lives. The government imposed taxes on these shares as if they were part of an American citizen's estate, but Lindgren argued this was incorrect because non-residents should be exempt from such taxation according to existing laws. The court disagreed with Lindgren’s argument and upheld the imposition of tax by ruling that while property located outside US borders is generally exempted from federal taxation for non-residents' estates under Section 402(b) Revenue Act 1926; stocks or bonds issued by domestic corporations are considered within US jurisdiction regardless where holder resides or his nationality status. Therefore, even though owners never resided in America nor held citizenship rights; their assets (shares) could still be taxed upon death due to being tied up with American corporate entities.

Dissent Summary
AI Abstract

In the dissenting opinion for Lindgren, Administrator v. United States et al., Justice Stone argued that the majority's decision was inconsistent with previous rulings and principles of maritime law. He contended that a seaman's right to wages should not be terminated by death unless explicitly stated in their contract, which it wasn't in this case. Furthermore, he disagreed with the majority’s interpretation of Section 4529 of Revised Statutes as only providing a cause of action for personal injury or wrongful death claims rather than wage disputes. According to him, this section also provides an independent statutory basis for recovery of unpaid wages due at time of death without any contractual stipulation necessary. Therefore, he believed that Lindgren should have been entitled to recover his deceased son’s earned but unpaid wages from his employers under federal maritime law.

Opinion written by Justice ETSanford
Decided: Feb 24, 1930
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