In the 1930 case of Beidler et al., Executors, v. South Carolina Tax Commission, the U.S. Supreme Court ruled on a dispute involving inheritance tax law in South Carolina and its application to non-residents. The executors of an estate belonging to a deceased Illinois resident who owned bonds secured by mortgages on real property located in South Carolina challenged the state's attempt to impose an inheritance tax on these assets. They argued that this was unconstitutional as it violated their right to due process under the Fourteenth Amendment because neither decedent nor his property were within jurisdictional reach of South Carolina at time of death. The court disagreed with this argument and upheld the constitutionality of applying such taxes, stating that states have authority over properties within their boundaries even if owners are non-residents or deceased individuals' estates are administered elsewhere. This ruling established precedent for taxation rights related to intangible personal property (like bonds) tied directly or indirectly through security interests (like mortgages) to tangible real estate situated within taxing jurisdictions regardless where owner resides or dies leaving them part of probate estate being settled outside those jurisdictions.

In the dissenting opinion for Beidler et al., Executors, v. South Carolina Tax Commission, Justice Stone argued that the majority's decision was inconsistent with previous rulings of the Court and violated principles of federalism. He contended that a state should not be allowed to tax property located outside its jurisdiction simply because it belonged to a resident at their time of death. According to him, this would lead to multiple taxation by different states on the same property which is unfair and burdensome for taxpayers. Furthermore, he believed that allowing such taxation infringes upon other states' rights over properties within their territories as they may also have legitimate claims on those assets based on where they are physically situated or used.