whom the property came and the receiver of the legacy. Thus, lineal issue or lineal ancestor, brother or sister, should pay at the rate of seventy-five cents for each and every hundred dollars of the clear value of the interest in the property. A descendant of a brother or sister of the decedent paid double this rate; an uncle or an aunt was taxed three dollars for every one hundred dollars passing; a great-uncle or a great-aunt, four dollars; and persons in any other degree of collateral consanguinity, or a stranger, or a body politic or corporate, five dollars. The only exemption made was in favor of a wife or husband. As only personal property was intended to be reached, all land and real estate escaped the duty.
The law of 1898 made important modifications in these rates and manner of assessing. In the first place, the rates fell only on legacies in excess of $10,000, a limit ten times larger than that of the law of 1862. The degrees of relationship were the same, the rates were copied from those of the earlier act, and the same exemption of property passing between husband and wife was admitted. But the idea of a progressive tax was ingrafted into the law. Thus, the old rates applied only to legacies of more than $10,000 and not more than $25,000. When the property passing was valued between $25,000 and $100,000 the rates were multiplied by one and a half; between $100,000 and $500,000, they were multiplied by two; between $500,000 and $1,000,000, they were multiplied by two and a half; and by three when the property was in excess of $1,000,000. In restricting the tax to personal property passing by inheritance the measure aims at a crude means of making the burdens of personal more nearly approach those of real property. No such consideration controlled the views of those responsible for the act, and, after all, it offers only a question of theoretical interest. The inheritance tax collected in many of the States may have owed their adoption to such an idea, but the United States, in taking up these duties, merely saw a means of obtaining revenue without regarding the actual results of the tax on the estates paying it.
"The inheritance tax in one form or another has come to stay, and new States are being added every year to the list of those which have adopted it. Five years ago it was found in only nine States of the Union—Pennsylvania, Maryland, Delaware, New York, West Virginia, Connecticut, Massachusetts, Tennessee, and New Jersey. During the first half of 1893 Ohio, Maine, California, and Michigan were added to the list, though the Michigan law was afterward annulled because of an unusual provision in the State Constitution which was not complied with. In 1894 Louisiana revived her former tax on foreign heirs; Minnesota adopted a con-
