120
if a claim for Eatste Duty hes s risen on the ceaser of the
said annuity on the death of Lady Chater, then the capital
sum necessary to produe 210,000 per aunum, caloulated at the
rate of 8 por centum per annum (being the Court rate of
interest) amounts to £125,000, which sum converted into hong
Kong dollars at the rate of 1/11 (being the rate prevailing
on the date of Lady Chater's death) amounts to $1,263,157.90
(Vide paragraph 8 of the above mentioned affidavit and the
Commissioner's letter of 20th May, 1935, to the solicitors
for the Trustees).
On this sum of $1,263,157.30 estate duty and interest
was prid by the frustees on the 23rd May, 1935, and the
Trustees intimated their intention of appealing against the
decision of the Commissiouer «
In accordance with the procedure laid down in th
rules onde on the 9th August, 1927, under the Batate Duty
Ordixone e, 1915 the effectiveness of which is preserved by
section 11(2) of the Interpretation Ordinance, No. 31 of 1911.
the Trustees filed on the 27th May, 1935, a Statement of
Grounds of Appeal.
On the 7th June, 1935, the Commissioner filed notice
of his determination to maintain in the whole the decision
appealed against, sm on the same day the Trustees filed
the requisite fetition to the Supreme Court.
The contentions of the Trustees as set forth in the
Statement of rounds of appeal and Petition are
(1) That by virtue of section 25 of Ordinence No. 3 of 1932
(the Estate Duty Ordinence, 1932) no estate duty was then
payable (1.e. payable on the death of Lady Chater).
(2) That if estate duty were payable by reason of the
5.