Final Determination of Domicil in the United States

Dr. John T. Dorrance died in 193o with residences in both New Jersey and Pennsylvania. Both states assessed inheritance taxes, amounting to about $17,000,000 each, on his intangible personalty, each claiming that he was domiciled within its borders. An appeal from the Pennsylvania tax was upheld by the Supreme Court of that state. Certiorari was denied by the United States Supreme Court on the ground that no federal question was involved; the Pennsylvania tax was accordingly paid. The instant action was an appeal from the New Jersey assessment, alleging that the adjudication by the Pennsylvania court was final as to the question of domicil. Held, that the Pennsylvania court was without jurisdiction in this matter since Dr. Dorrance was domiciled in New Jersey, and that therefore full faith and credit need not be given to the decree and the New Jersey tax was validly assessed.\u27 In re Dorrance\u27s Estate. 17o Atl. 601 (N. J. Prerogative Ct. 1934)