In the 1911 case of Chase v. Wetzlar, Executor, the United States Supreme Court was tasked with determining whether a New York law that imposed inheritance taxes on out-of-state property held by New York residents violated the Due Process Clause of the Fourteenth Amendment. The plaintiff in this case was an executor for a deceased resident of New York who owned bonds issued by corporations located outside of New York state. The defendant argued that these bonds should be subject to inheritance tax under state law. The court ruled in favor of Wetzlar, upholding the constitutionality of taxing intangible personal property (like stocks and bonds) even if they are physically located outside the state where their owner resides at death. They reasoned that such assets have no real location but exist merely as rights enforceable through legal action; therefore it is reasonable to consider them part and parcel with their owner's domicile for taxation purposes. This decision set important precedent regarding states' ability to levy estate or inheritance taxes on intangible assets regardless where those assets were technically "located." It also clarified how courts should interpret what constitutes due process when dealing with matters related to taxation.

The dissenting opinion in the case of Chase v. Wetzlar, Executor argued that the majority's decision to uphold a lower court ruling was incorrect because it failed to properly interpret and apply existing laws regarding inheritance tax. The dissenting justices believed that the deceased's intent should have been considered more heavily when determining whether or not certain assets were subject to taxation. They also disagreed with how the majority interpreted language within relevant statutes, arguing their interpretation was too broad and did not align with legislative intent. Furthermore, they contended that this broad interpretation could lead to unfair outcomes in future cases by potentially subjecting individuals' estates to double taxation.