Opinion
November 22, 1946.
Appeal from State Tax Commission.
At the time of the delivery of the deed, petitioner held mortgages upon the property conveyed to the extent of $9,300. No new or other consideration passed at that time. The settlement of an action by Bertha Kosoff against petitioner about fourteen years later and the payment of $1,000 did not, under the circumstances, furnish any new consideration which would justify the imposition of any additional recording tax. Determination and order of the State Tax Commission annulled, with $50 costs and disbursements. All concur.