The U.S. Supreme Court case Bohler, Tax Collector of Richmond County, Georgia, et al. v. Callaway, Executor of the Estate of J.B White, Deceased in 1924 revolved around a dispute over inheritance tax assessment on property located outside the state of Georgia but owned by a resident within the state at their time of death. The executor to Mr. White's estate argued that this was unconstitutional as it violated due process rights under the Fourteenth Amendment and infringed upon federal jurisdiction over interstate commerce and maritime matters (as some properties were ships). However, the court ruled against them stating that states have power to levy taxes on personal property irrespective of its location if owned by residents within their borders at time of death - thus upholding Georgia's right to impose an inheritance tax on out-of-state assets.

In the dissenting opinion for Bohler v. Callaway, Justice McReynolds disagreed with the majority's ruling that a state tax on intangible property held outside of Georgia by a resident was unconstitutional. He argued that it is within the rights of states to levy taxes on their residents' personal properties regardless of where they are located. The justice contended that this principle had been upheld in previous cases and should not be overturned without compelling reasons. Furthermore, he pointed out inconsistencies in how different types of property were treated under the majority's interpretation, which could lead to unfair taxation practices. Ultimately, Justice McReynolds believed that each state has sovereignty over its own fiscal policies and should have broad discretion in determining what constitutes taxable property within its jurisdiction.