Commonwealth, Department of Taxation v. Lewis

156 S.E.2d 589, 208 Va. 221, 1967 Va. LEXIS 207
CourtSupreme Court of Virginia
DecidedSeptember 8, 1967
DocketRecord 6492
StatusPublished
Cited by7 cases

This text of 156 S.E.2d 589 (Commonwealth, Department of Taxation v. Lewis) is published on Counsel Stack Legal Research, covering Supreme Court of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth, Department of Taxation v. Lewis, 156 S.E.2d 589, 208 Va. 221, 1967 Va. LEXIS 207 (Va. 1967).

Opinion

Gordon, J.,

delivered the opinion of the court,

*222 About two years before her death, Page L. Jennings made a gift of certain assets on which the State of Virginia assessed and collected a gift tax. These assets were included in her estate for death tax purposes because the gift was found to have been made in contemplation of death. Mrs. Jennings’s Administrators c.t.a. claimed a credit against the Virginia death tax in the amount of the gift tax previously paid, which the Department of Taxation denied. Upon the Administrators’ application the trial court held that the estate was entitled to the credit. The Commonwealth appeals.

For an understanding of the controversy we will describe the alternate death taxes imposed by the State of Virginia under Code § 58-152 (and related sections) and Code § 58-162. Va. Code Ann. §§ 58-152, -162 (Repl. vol. 1959). We will also identify the section under which the death tax was assessed against Mrs. Jennings’s estate.

Code § 58-152 imposes death taxes upon the shares passing to beneficiaries under a decedent’s will. Code § 58-162 imposes an alternate State death tax designed to “pick-up” for the State treasury the maximum federal estate tax credit allowable under the United States Internal Revenue Code for death taxes paid to the State. 26 U.S.C. § 2011 (1964). Code § 58-162, the “pick-up” statute, fixes the tax levied thereunder at an amount equal to the maximum federal credit. 1

*223 Code § 58-162 provides that a death tax shall be assessed under Code § 58-152 if the maximum federal credit is smaller than the death taxes assessable under Code § 58-152. But where, as was true for Mrs. Jennings’s estate, the death tax assessable under the “pick-up” statute is greater than the death tax assessable under Code § 58-152, the State assesses a death tax under the “pick-up” statute.

Turning to the facts of this case in more detail, we find that in 1959 Mrs. Jennings transferred certain assets to an inter vivos trust. Following Mrs. Jennings’s death in 1961 her Administrators c.t.a. filed a gift tax return and paid a Virginia gift tax of $24,850 on the transfer of those assets. They also filed a Virginia inheritance tax return, on the basis of which the Department of Taxation assessed a tax of $117,695.44 against her estate under the “pick-up” statute.

After an audit the Internal Revenue Service determined that Mrs. Jennings made the 1959 transfer in contemplation of death. The Service therefore included the assets transferred in 1959, on which the Virginia gift tax of $24,850 had been paid, in the gross estate for federal estate tax purposes and increased the federal estate tax assessment.

Because of this adjustment and other adjustments made by the federal authorities, the maximum available federal credit was increased from $117,695.44 to $183,329.12. The Department of Taxation therefore increased the Virginia death tax assessment to $183,329.12. The Administrators voluntarily paid $158,479.12. They contended that such payment, together with a $24,850 gift tax credit which the Administrators claimed to be available under Virginia law, satisfied the total death tax owing. After the Department of Taxation denied the credit, the Administrators paid $24,850 under protest. They then instituted this proceeding seeking a refund of $24,850, which the trial court granted.

Mrs. Jennings’s Administrators claimed the gift tax credit under Code § 58-158:

“§ 58-158. Credits.—In case a tax has been imposed under chapter 6 of this title upon any gift and thereafter upon the death of *224 the donor the amount thereof is required by any provision of this chapter to be included in the gross estate of the decedent then there shall be credited against and applied in reduction of the inheritance tax which would otherwise be chargeable against the estate of the decedent or the respective shares of the beneficiaries thereof under the provisions of this chapter an amount equal to the tax paid with respect to such gift.” Va. Code Ann. § 58-158 (Repl. vol. 1959).

The Commonwealth argues that the gift tax credit provided under Code § 58-158 is available only when death taxes are assessed under Code § 58-152, not when the tax is assessed under the “pick-up” statute.

The Commonwealth bases its argument in part on the distinction between an inheritance tax and an estate tax. The Commonwealth points to the language of Code § 58-158 that allows the gift tax credit “in reduction of the inheritance tax” that would otherwise be assessable. [Emphasis supplied.] The Commonwealth says that a tax assessed under Code § 58-152 is truly an inheritance tax because it is a succession tax imposed upon the beneficiary’s right to succeed to a share of the estate, while the death tax assessed under the “pickup” statute is truly an estate tax because it is imposed on the decedent’s right to transmit property. See Commonwealth v. Morris, 196 Va. 868, 871, 86 S.E.2d 135, 137 (1955), cited by the Commonwealth for these propositions.

[1] We agree with the Commonwealth’s distinction between an inheritance tax and an estate tax. And we admit that the “pick-up” statute is truly an estate tax, a tax imposed upon the right to transmit property. But this admission does not lead to the conclusion advocated by the Commonwealth.

[2] The Virginia Legislature saw fit to label the tax imposed under the “pick-up” statute an “inheritance” tax. It applied this label in the words of the statute itself: “Such minimum inheritance tax imposed by this State, which is hereby imposed by this chapter * * * This section shall always be so construed as not to increase the total amount of inheritance taxes, State and federal, payable upon the estates of decedents # # *” (Emphasis supplied; see Code § 58-162, quoted in part in footnote 1, supra.)

The language of a statute should of course be given the meaning intended by the Legislature. So when the Legislature directed in *225 Code § 58-158 that certain gift taxes previously paid “shall be credited against and applied in reduction of the inheritance tax” otherwise collectible, the Legislature intended to refer not only to the true inheritance tax levied under Code § 58-152, but also to what it had labeled the “inheritance tax” levied under the “pick-up” statute.

The Legislature made its intent even clearer by these words in Code § 58-158: “in reduction of the inheritance tax which would otherwise be chargeable against the estate of the decedent or the respective shares of the beneficiaries thereof under the provisions of this chapter”.

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Bluebook (online)
156 S.E.2d 589, 208 Va. 221, 1967 Va. LEXIS 207, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-department-of-taxation-v-lewis-va-1967.