Cory

The Controller has appealed from a judgment sustaining an objection by the executor of the Estate of F. Harold Pinska, deceased, to a report of the inheritance tax referee which stated that supplemental inheritance taxes were due on assets discovered after the filing of the inventory and appraisement.

One asset of the estate was a fixed time certificate of deposit purchased by decedent from Crocker National Bank on April 13, 1974, for $229,000. The certificate was payable October 9, 1974, with interest at 9Vi percent per annum. It was provided in the certificate that “Neither the deposit evidenced hereby nor the interest thereon, may be withdrawn prior to maturity.’’ Decedent died on August 30, 1974. The court found that there was “no ‘market’ in which a TCD of the type here involved can be *948 traded, bought or sold.” The executor held the certificate until maturity, and received interest at maturity, of which $8,447 represented interest accrued to the date of death.

The question is whether interest on an unmatured time certificate of deposit is a property right subject to inheritance taxes. The Controller argues that such interest is a valuable property right owned…