text: The appeal is heard on an agreed statement. The will of decedent left one-sixth of the residue of her estate to ‘The Salvation Army of Cleveland, Ohio.’ There is no such corporation or organization in the State of Ohio having power to receive, control or manage property of any kind. Accordingly the bequest was ordered distributed to the Salvation Army, a corporation organized and existing in the State of New York, less, however, the sum of $3,498.13 claimed by respondent by way of an inheritance tax.
  The question on appeal is whether the gift to the New York corporation, which operates in a ‘reciprocal’ state is subject to the tax because the fund is to be used for charitable purposes in Ohio, which is a non-reciprocal state.