
    PEOPLE ex rel. FARMERS’ LOAN & TRUST CO. et al., Appellants, v. WELLS et al., Respondents.
    (Supreme Court, Appellate Division, First Department.
    May 20, 1904.)
    Certiorari by the people, on the relation of the Farmers’ Loan & Trust Company and others, as executors of the will of Eugene A. Hoffman, deceased, against James L. Wells and others, as tax commissioners, to review the assessment of decedent’s estate for transfer taxation. From an order quashing the writ, relators appeal. Affirmed. William H. Harris, for appellants. George S. Coleman, for respondents.
   PER CURIAM.

Order affirmed, with costs, on the opinion of the court below. 87 N. Y. Supp. 745.

PATTERSON, J., concurs in result.

VAN BRUNT, P. J.

I dissent. I know of no statute or rule of law which makes personal property taxable anywhere but where its owner resides.  