Taxation: Valuing a Favorite (Rich) Son

In the eight years since the death of Billionaire Howard Hughes, the state of Texas, where Hughes was born, has claimed him as a resident and dunned his estate for inheritance taxes and penalties of $100 million—despite the fact, acknowledged by Texas officials, that Hughes spent no more than 48 hours in the state after 1926. Disputing Texas' claim was California, where Hughes lived between 1925 and 1966, and where the inheritance-tax rate is 24% compared with Texas' 16%. California coveted a possible tax bite of $180 million.

After spending millions in legal fees and...

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