Argument for Complainant. 308 U.S. 4. A State may not invoke the original jurisdiction of this Court to enforce the individual rights of its citizens. P. 17. 5. Federal jurisdiction to render a declaratory judgment depends on the existence of a controversy in the constitutional sense. Id. 6. A State can not be brought into court by making its citizens parties to a suit not otherwise maintainable against the State. Id. 7. An action by a State to recover money from citizens of another State will not be entertained by the Court in the absence of facts showing that resort to the original jurisdiction is necessary for the protection of the plaintiff State. P. 18. In the present instance, it does not appear that Massachusetts is without a proper and adequate remedy in the Missouri courts or the federal District Court in Missouri. P. 19. 8. Clause 2 of §2 of Article III of the Constitution merely distributes the jurisdiction conferred by clause 1. Id. 9. The orginal jurisdiction of this Court, in cases where a State is a party, refers to those cases in which, according to the grant of power made in Art. III, § 2, cl. 1, jurisdiction might be exercised in consequence of the character of the party, and an original suit might be instituted in any of the federal courts. Cohens v. Virginia, 6 Wheat. 264. Id. 10. The objection that the courts in one State will not entertain a suit to recover taxes due to another or upon a judgment for such taxes, goes not to the jurisdiction but to the merits, and raises a question which the district courts are competent to decide. P. 20. Motion for leave, denied. ON MOTION for leave to file an original bill in this Court and the return to an order to show cause. Mr. Edward O. Proctor, Assistant Attorney General of Massachusetts, with whom Mr. Paul A. Dever, Attorney General, was on the brief, for complainant. Under Graves v. Elliott, 307 U. S. 383, decedent's right to revoke had the attribute of property, and control of her person and estate at the place of her domicil afforded constitutional basis for imposition of the tax. Under that case and Curry v. McCanless, 307 U. S. 357, Missouri also can tax the transfer, though whether its 1 Argument for Complainant. statutes exercise that power with respect to the present trusts, in view of the reciprocity provision of the statute, is another question. As the Massachusetts tax is imposed upon the trustees, who are residents of Missouri, Massachusetts can enforce the tax only by recourse to the Missouri or federal courts. The trustees deny their liability to pay, on the ground that Massachusetts has no jurisdiction to impose it. There exists, therefore, a controversy between that State and citizens of Missouri. The purpose of vesting in the courts of the United States jurisdiction of suits by one State against the citizens of another "was to enable such controversies to be determined by a national tribunal, and thereby to avoid the partiality, or suspicion of partiality, which might exist if the plaintiff State were compelled to resort to the courts of the State of which the defendants were citizens." Massachusetts v. Mellon, 262 U. S. 447, 480, 481; Wisconsin v. Pelican Ins. Co., 127 U. S. 265, 289; Chisholm v. Georgia, 2 Dall. 419, 475; Story on the Constitution, §§ 1638, 1682. And if the facts present such a case, the Court may not deny jurisdiction because numerous similar cases might "be brought within its cognizance." Minnesota v. Hitchcock, 185 U. S. 373. A suit against an individual to collect a tax clearly presents a justiciable controversy determinable "according to accepted doctrines of the common law or equity systems of jurisprudence." United States v. Chamberlin, 219 U. S. 250; Milwaukee County v. M. E. White Co., 296 U. S. 268, 271; Meredith v. United States, 13 Pet. 486; Dollar Savings Bank v. United States, 19 Wall. 227; United States v. Philadelphia & Reading R. Co., 123 U. S. 113. A judgment for a tax is one which is entitled to full faith and credit under the Constitution. Milwaukee County v. M. E. White Co., 296 U. S. 268. Argument for Complainant. 308 U.S. The Massachusetts inheritance tax is a statutory liability quasi contractual in nature, subject to enforcement by suit. The rule, adopted in some jurisdictions but denied in others, that the courts of one State will not enforce the revenue laws of another State, has been severely criticized (29 Col. L. R. 782; 48 Harv. L. R. 828) and its validity is an open question in this Court. Milwaukee County v. M. E. White Co., 296 U. S. 268, 275; Moore v. Mitchell, 281 U. S. 18, 24. The rule of Wisconsin v. Pelican Ins. Co., 127 U. S. 265, should not be extended to a suit for enforcement of revenue laws. Milwaukee County v. M. E. White Co., supra. There is presented a controversy between Massachusetts and Missouri. In view of recent decisions (Curry v. McCanless, supra; Graves v. Elliott, supra; Worcester County Co. v. Riley, 302 U. S. 292, 299; New Jersey v. Pennsylvania, 287 U. S. 580) the States, having surrendered their rights to make treaties inter sese, must find their only remedy against double taxation in reciprocal legislation. First National Bank of Boston v. Maine, 284 U. S. 312, 334; Kidd v. Alabama, 188 U. S. 730, 732. Both Massachusetts and Missouri have resorted to this expedient. Massachusetts and its residents, therefore, are entitled to the immunity offered by the Missouri statute. If the evils of multiple taxation are to be solved by reciprocal legislation of the States, as this Court has itself suggested, it is essential that there be a forum where recalcitrant States may be compelled to observe the reciprocity their legislatures have provided. The Supreme Court is the only available forum. If the Court has jurisdiction upon either ground but not the other, the jurisdiction is not lost because of the joinder of parties not necessary to such jurisdiction. 1 Argument for Respondents. Mr. Harry W. Kroeger, with whom Mr. Daniel N. Kirby was on the brief, for St. Louis Union Trust Co., Trustee, et al., respondents. The controversies in this case are justiciable because they are of a civil nature and arise between States of the Union and between a State and citizens of another State. They exist notwithstanding the absence of constitutional restraints on double taxation. Distinguishing Curry v. McCanless, 307 U. S. 357; Graves v. Elliott, 307 U. S. 383. Because of the facts in this case, and the reciprocal exemption contained in the law of Missouri, there can here be only one tax, if in truth there can be any tax at all. In such a situation a controversy arises appropriately to be decided by a court upon an analogy to interpleader under the principle recently decided by this Court in Texas v. Florida, 306 U. S. 398. Controversies between the States of Massachusetts and Missouri arise because each denies the right of the other to tax. A controversy arises from the assertion by Massachusetts of the validity of its tax laws in Missouri. Throughout the Eighteenth and Nineteenth Centuries English courts have announced the doctrine in dicta that no nation will take notice of the revenue laws of another. In America the doctrine has been followed and applied in Ludlow v. Van Rensselaer, 1 Johnson 94; Maryland v. Turner, 132 N. Y. S. 173; Colorado v. Harbeck, 232 N. Y. 71; New York Trust Co. v. Island Oil & Transport Corp., 11 F. 2d 698; Moore v. Mitchell, 30 F. 2d 600; 281 U. S. 18. This Court has found it unnecessary to decide whether a State might have extraterritorial enforcement of its revenue laws in an original action outside the taxing State, as distinguished from a suit on a judgment obtained in the taxing State on personal service. Moore v. Mitchell, supra; Milwaukee County v. M. E. White Argument for Respondents. 308 U.S. Co., 296 U. S. 268. The issues, as suggested by Colorado v. Harbeck, 232 N. Y. 71, and Moore v. Mitchell, supra, go deeper than objections to extraterritorial collection. They involve questions of the vitality of the taxing law itself when sought to be applied to raise obligations and impose liens within the confines of another State. The attempt of Massachusetts here is to impose a contractual liability upon trustees who neither made themselves amenable to, nor sought the protection in any way of, the Commonwealth, and to reach over into Missouri in the attempted impressment of a lien on assets held in Missouri. Massachusetts is attempting to base her right upon revenue laws claimed to have extraterritorial effect. A controversy arises from the denial by Missouri of the effect of her reciprocity statute. The extent of reciprocal legislation was commented upon in Farmers Loan & Trust Co. v. Minnesota, 280 U. S. 204, where it was said that thirty-five States had already in some form granted relief against double taxation. In view of the holding in Curry v. McCanless, supra, and Graves v. Elliott, supra, the need for reciprocal legislation to avoid the evils of double taxation becomes of paramount importance. See, Orr, "Reciprocal Exemptions from Inheritance Taxation," 18 Boston University Law Rev. 39. Has not Massachusetts an interest in the question whether Missouri legally withholds the exemption granted by her statute? Enactment of mutual reciprocity laws is assumption of mutual obligations between the States. There was something of the nature of a continuing, although revocable, offer to other States, for the duration of a reciprocity law, to grant exemptions in respect of property of citizens of other States, if the States of their domiciles granted similar exemptions in respect of property of |