Norwich bulletin., 1915-09-18
ESTATES OF DECEASED
 PERSONS WITHIN LAW
Tax of Four MiIIs Is Applicable, Says
 Attorney General.

At the request of State Treasurer F. s. Chamberlain, Attorney General George B. Hinman has given an opin- ion that the treasurer should accept from the administrators and execu- tors of the estates of persons deceased since August 1, 1915, payment of tax as provided in the law passed by the recent legislature. The opinion, in full, follows:
 Hartford, Sept. Is, 1915. Hon. Frederick s. Chamberlain, State
 Treasurer.
 Dear Sir: You ask my advice as to whether you should accept payment from the administrator or executor of the estate of a person deceased since August l, 1915, of tax at the rate of four mills per annum, as provided by Section 5 of Chapter 293 of the Public Acts of 1915, upon property of said estate upon which no tax has been paid during the five years last preced ing.
 Said Section read as follows:
 Any person may file with the state treasurer a list of his property liable to taxation upon which no tax has been paid during the five years last preceding the date of filing such list, and may pay four mills per annum thereon for said five years, and tho treasurer shall receipt for such taxes, provided the provisions of this section shall not continue in force after Sep | tember 30, 1915"
 The determining question is as to l in said section includes the estate of a deceased person. The word per son. in its legal significance is a gen. eric term, and includes artificial as well as natural persons.
 Abbot's Law Dictionary, z71. Douglass Pacific, etc, Co, Cal. Planters. Bank Andrus. 8 Port. | (Ala-) 404.
 Barry Minahan, 127 Wis, 570-577. Section 1 of the General Statutes of 1902 provides that, in construing our | statutes, the word person" may ex- | tend and be applied to communities companies, corporations, public or pri- | vate, societies and associations. This provision does not constitute a spe- cial definition excluding all subjects not enumerated but indicates an in- | to the word.
 It seems reasonable that the estate | of a deeedent should be regarded as an artificial person; it is a creature of law for the purpose of enabling a disposition of the assets to be prop erly made, and although natural per- sons. as heirs, devisees and creditors have an interest in the property, the artificial creature is a distinct and le- gal entity. The interest, which nat ura1 persons have In It Is not com plete until there has been due ad- ministration.
 Thus the estate, being a collection of property to which the law attributes the capability of having rights and duties, falls within the definition oi an artificial person.
 Bouvier's Law Dictionary, D. 661.
 Billings vs. State, 1o7 Ind 54.
 Barry vs. Minahan. 127 Wis. 57o- 577.
 It is also reasonable, having in view the reason and purpose of the aci under consideration, that the relief afforded by said Section to the per son owning the property in question and who at any time from the taking effect of the act until September a( might have taken the benefit there of should not be defeated by his death but preserved to his estate, un- Il less such a policy plainly contravenee the provisions Of the act.
 II I am therefore of the opinion tha- the estate of Q deceased person should be construed as included within the provisions of said Section of Chap. ter 293. and that payment at the rate therein provided may be properly ac. cepted and receipted. for.
 It is to be considered, however that under the provisions of SectioI of said act, the town, consolidated town and city. or consolidated towr and borough in which the deceden last resided. has an interest in the in.