The U.S. Supreme Court case Bankers Trust Company et al., Executors of McMullen, v. Blodgett, Tax Commissioner of the State of Connecticut (1922) revolved around a dispute over inheritance tax law in Connecticut. The executors of the estate for George E. McMullen challenged the state's taxation on securities that were physically located outside Connecticut at the time of his death but owned by him as a resident within it. They argued this was an unconstitutional imposition by the state under both Due Process and Commerce Clauses since these assets were not within its jurisdictional reach. However, in ruling against them, Justice Holmes opined that while physical location could be relevant to tangible property taxes, intangible properties like stocks and bonds are different because they have no fixed location per se; their value is tied more to ownership rights than geographical positionality. Therefore he concluded that such assets can indeed be taxed based on where their owner resides regardless if they're physically held elsewhere - thus upholding Connecticut's right to levy inheritance tax on out-of-state securities belonging to its residents.

In the dissenting opinion for Bankers Trust Company et al., Executors of McMullen, v. Blodgett, Tax Commissioner of the State of Connecticut (1922), Justice Holmes argued that a state has no right to tax property located outside its jurisdiction. He contended that such taxation is an infringement on the sovereignty of other states and violates principles established by international law. In this case, he disagreed with the majority's decision to uphold Connecticut's inheritance tax applied to securities physically held in New York but owned by a deceased resident of Connecticut. Holmes believed it was not within Connecticut’s power to levy taxes on these out-of-state assets because they were beyond its territorial limits and control. His view emphasized respect for geographical boundaries in determining taxing authority.