Washington Law Review


In addition to inheritance and gift tax subjects, the Board of Governors requested the committee to consider the impact which the decision of the Supreme Court of the United States in Mullane v. Central Hanover Bank and Trust Co., 94 L. Ed. 865, might have on the validity of decrees of distribution in probate proceedings. The committee took no action on this problem because of the inclusion in the new rules adopted by the Washington Supreme Court of Rule 41 of the Rules on Pleading, Practice and Procedure. Under this rule notice similar to that approved by the United States Supreme Court is now required.

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