Migratory Millionaire

After eccentric, peg-legged Colonel Edward H. R. ("Ned") Green, son of fabulous old Miser Hetty Green, died at 67 in Lake Placid, N. Y. two Junes ago, the U. S. Government collected taxes of $17,520,987 on his $36,137,335 net estate. Four States--as well as his wife and sister--also commenced a fearsome tangle of litigation for their shares (TIME, April 19, 1937, et seq.).

First job was to determine which State was "Ned" Green's legal domicile--New York, where he maintained a $27,000-a-year apartment at the Sherry-Netherland Hotel; Florida, where his Star Island mansion at Miami Beach cost a small fortune; Massachusetts, where in 1921 he built a house requiring 30 servants; or Texas, where he spent most of his time between 1893 and 1910 but kept only a $5-a-month room at Terrell in later years.

Appointed special master to recommend on the issue to the Supreme Court of the U. S. was Lawyer John S. Flannery of Washington. Last week Master Flannery made his report, and Massachusetts, with a tax claim of $4,947,008, was his pick.

Dodging State taxes was, reported Master Flannery, a preoccupation of Colonel Green, as it had been of his mother. He had managed to pay no income taxes to any State by the simple process of citing to the tax collectors of each his residence in the others, especially Texas. Sharply condemning "migratory millionaires," Master Flannery opined that "conduct is of greater evidential value than mere declaration of intent."

The Supreme Court will accept briefs from the three disappointed States if they protest Master Flannery's findings. Should their claims be allowed as well as Massachusetts', Ned Green's estate will fall $1,589,000 short of paying them all.

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