Estate of Mears

In Estate of Mears (1979) 90 Cal. App. 3d 885, the court found no equal protection violation where a statute provided an unconditional exemption from inheritance taxation for certain property owned by residents of other states, but not for property owned by residents of foreign countries. The court found the distinction was rationally related to the state's goals of preventing estates from being subject to double taxation and maintaining the good will with other states that results from California's reciprocity provision. (Id. at pp. 890-891.)