In re Kessler’s Estate

Louis Kessler acquired stock while living with his wife in California under community-property law from 1947 to 1957; after the couple moved to Ohio, Louis died four years later, and his estate's executor determined that half the stock became his wife's property under California community-property law. The trial court found the wife owed no Ohio succession tax on that one-half interest once it became her exclusive property, and Ohio's Tax Commissioner appealed.