In the case of Lord v. Glynn, Comptroller of the State of New York (1908), the U.S Supreme Court dealt with a dispute over inheritance tax. The plaintiff, Lord, was an executor to an estate that included stocks in corporations based outside New York but doing business within it. Upon death, these stocks were transferred to beneficiaries who resided out-of-state and thus did not pay any transfer taxes on them as per New York law at that time which only taxed transfers made within its jurisdiction. The defendant argued for taxation under a new amendment allowing taxation on all property owned by decedents regardless of where their beneficiaries lived or where transactions took place. However, this amendment came into effect after the testator's death and before his will was probated. The court ruled in favor of Lord stating that imposing such tax would be unconstitutional as it violated due process rights under Fourteenth Amendment since neither decedent nor recipients had sufficient connection with state when he died or when they received properties respectively; hence state lacked jurisdictional basis for taxing those transfers.

In the dissenting opinion for the case of Lord v. Glynn, it was argued that New York's inheritance tax law did not violate the Fourteenth Amendment’s due process clause as claimed by the plaintiff. The justice believed that states have a right to impose taxes on their residents and property within their jurisdiction, including inheritances or transfers of property after death. He disagreed with majority’s view that this taxation power should be limited when dealing with non-residents who own stock in corporations operating within state boundaries. In his perspective, such stocks represent tangible assets subject to state control and therefore can be taxed accordingly without infringing upon constitutional rights. Furthermore, he contended that if every claim against an estate must be physically present in a state for it to levy an inheritance tax then most debts would escape taxation entirely – something he saw as neither fair nor logical.