I was referring to the occasion when it came up in the Committee this year, and not to two years ago. My hon. Friend who seconded the new Clause said that it would bring the law into relation with the facts, but I think he is mistaken, because it is not the fact that the moment a testator dies his residuary legatee becomes the real owner of his property. It is, on the contrary, a general principle of law that a residuary legatee has no interest in any of the property of the testator until the residue has been ascertained, his right being merely to have the estate properly administered and applied to his benefit when the administration is complete. That is a recognised principle of law and has many important results, among them the result that the estate comes to the legatee as capital and not as income, and surtax is not charged on it for that reason. I am sure that my hon. Friend would be reluctant to consider any change in the law in one respect to deal with the issue that has been raised by the hon. Member for South Croydon (Mr. H. Williams) until the whole question of the prolonged administration of estates has been considered. It is, as has been rightly stated, being considered at the present time, and it would be a great mistake to deal with such a matter piecemeal.

An important exception to this general principle of law was made in 1922 on behalf of charitable bequests. The charities are considered to be the owners of the property of the testator one year after the death of the testator, however long it may take for the estate to be wound up. After that year, they are not liable to income tax. That was granted as a result of the appeal from the hospitals, through a committee of the voluntary hospitals, who put it forward in that shape, and they have been very grateful because they have benefited considerably by the concession. The present appeal does not come from them, but from my hon. Friend the Member for South Croydon and from a chartered accountant, I think, who is a constituent of his and who wound up an estate which had been left to charity, and as the result of the prolonged administration of the estate my hon. Friend went so far as to say that the charity had been defrauded of a large sum. I think "defrauded" was a rather strong word to use.

A Motion of this kind is always certain of a favourable reception in all parts of the House. It is a great pleasure for everybody to be charitable, and it is a greater pleasure when we are being charitable with other people's money and not with our own. This is an appeal for us to amend the law in such a way as to make a compulsory contribution to charity from the ordinary taxes. The State would lose. I am not in a position to say, because it is very difficult to ascertain, what the annual loss would be, but the State would lose. The taxpayer would be compelled to pay more in a direction in which he has already made a considerable concession, and in which, so far as I am aware, there is no very widespread demand from the charities concerned in favour of the plea. I do not deny that we should be very glad if this concession could be made, and no doubt there are cases such as that brought to the notice of my hon. Friend the Member for South Croydon in which a certain amount of hardship has been caused. But we do not think a case has been sufficiently made out for a concession to be made to-day, and therefore we cannot agree to add this Clause to the Bill.