Oliver Wendell Holmes, Jr.

“ The assessments complained of were for City and State taxes upon the corpus of a trust fund created by the will of a citizen of Maryland resident in baltimore at the time of her death. This will bequeathed to the Safe Deposit & Trust Company of Baltimore $80,000 in trust to pay the income to the petitioner for life, then to her daughters for their lives, and, upon the death of the last survivor, to divide the principal between the descendants then living of the daughters per stirpes. ”

“ The will was proved in Maryland and in 1914 was admitted to probate in the Corporation Court of Norfolk as a foreign will. The property held in trust has remained in Maryland and no part of it is or ever has been in Virginia. ”