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N.Y. EX REL. COHN v. GRAVES

No. 404.

300 U.S. 308 (1937)

57 S.Ct. 466

81 L.Ed. 666

NEW YORK EX REL. COHN v. GRAVES ET AL.

Supreme Court of United States.

Decided March 1, 1937.

Attorney(s) appearing for the Case

Mr. Maurice Cohn, with whom Messrs. David Cohn, Daniel J. Kenefick, Randolph E. Paul, and Watson Washburn were on the brief, for appellant.

Mr. Joseph M. Mesnig, Assistant Attorney General of New York, with whom Mr. John J. Bennett, Jr., Attorney General, and Mr. Henry Epstein, Solicitor General, were on the brief, for appellees.

MR. JUSTICE STONE delivered the opinion of the Court.

This case presents the question whether a state may constitutionally tax a resident upon income received from rents of land located without the state and from interest on bonds physically without the state and secured by mortgages upon lands similarly situated.

Section 351 of Article 16 of the New York Tax Law (N.Y. Laws 1919, c. 627), imposes a tax upon the "entire...

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