A tax laid upon the happening of an event, as distinguished from its tangible fruits, is an indirect tax which Congress, in respect of some events... undoubtedly may impose

—it was ruled that property held by husband and wife by an estate in the entirety was taxable as a part of the deceased husband's estate.

—"the effect of passing to the survivor substantial rights, in respect of the property, theretofore never enjoyed by such survivor.*** Thus the death of one of the parties to the tenancy became the `generating source'of important and definite accessions to the property rights of the other. "

There has been no showing that any part of the land constituting the tenancy by the entirety had, prior to the creation of the tenancy, ever belonged to the surviving spouse, and, by the express provisions of section 302 of the Revenue Act of 1924, the full value of the property held by the decedent and his wife must be included in the gross estate of the decedent for estate …

The question here, then, is not whether there has been, in the strict sense of that word, a "transfer" of the property by the death of the decedent, or a receipt of it by right of succession, but whether the death has brought into being or ripened for the survivor, property rights of such character as to make appropriate the imposition of a tax upon that result (which Congress …

Comparison of § 302 with corresponding provisions of earlier Acts warrants the conclusion that (d) is not a mere specification of something covered by (a) but that it covers something not included therein.

Even if we assume one's human capital should be treated as personal property, it does not appear that this tax is upon ownership; rather, as the Government points out, Murphy is taxed only after she receives a compensatory award, which makes the tax seem to be laid upon a transaction.

A rule of property established by decisions of the state courts or by state statutes is binding on the Federal courts.

—the use, possession and enjoyment of the joint property which was joint before the death was thereby made exclusive in the survivor, and thus constituted a "definite accession to the property rights" of the survivor.

—case the court points out that the estate by the entireties was created after the passage of the act levying the tax.