Note 517 — AMENDMENT 14 (continued 2)

240 U.S. 625, 631 (1916).—A decision rendered in 1920 which is seemingly in conflict was Wachovia Bank & Trust Co. v. Doughton, 272 U.S. 567, in which North Carolina was prevented from taxing the exercise of a power of appointment through a will executed therein by a resident, when the property was a trust fund in Massachusetts created by the will of a resident of the latter State. One of the reasons assigned for this result was that by the law of Massachusetts the property involved was treated as passing from the original donor to the appointee. However, this holding was overruled in Graves v. Schmidlapp, 315 U.S. 657 (1942).