George Shiras, Jr.

“ Whether the United States, in the exercise of the power of taxation, can be estopped by a contract that such power shall not be exercised, we need not consider, because the contract in this case does not, as we view it, mean that a state may not, or the United States may not, tax inheritances and legacies, regardless of the character of the property of which they are composed. ”

“ If a state inheritance law can validly impose a tax measured by the amount or value of the legacy, even if that amount includes United States bonds, the reasoning that justifies such a conclusion must, when applied to the case of a Federal inheritance law taxing the very same legacy, bring us to the same conclusion. ”

“ Moore, the tax imposed under the act of June 13, 1898, is not invalid as a direct, unapportioned tax, nor for want of uniformity, nor as an infringement upon the laws of the states regulating wills and descents, then the tax upon legacies or bequests descendible under and regulated by state laws is valid, even if such legacies incidentally are composed of Federal bonds.
It cannot be denied that the government of the United States has, and has heretofore exercised, the power to tax its own bonds. ”