In the 1931 case Coombes v. Getz, the U.S. Supreme Court addressed a dispute over inheritance and property rights. The plaintiff, Mrs. Coombes, was a British citizen who had inherited California real estate from her deceased son-in-law Mr. Getz in 1923 but did not receive any income from it until 1926 due to litigation with other family members over ownership of the property. The issue before the court was whether Mrs. Coombes owed U.S federal income tax on this backdated rental income under existing laws which exempted non-resident aliens from paying taxes on certain types of American-sourced income unless they were engaged in business within America or earned their money through personal services performed there. The Supreme Court ruled that Mrs.Coombes' rental earnings were indeed taxable because she had been "engaged in business" within America by virtue of owning and renting out Californian real estate - even though she lived abroad and did not personally manage her properties. This decision clarified that foreign landlords could be considered as conducting business activities inside United States for tax purposes if they owned American properties generating rental incomes regardless of where they resided or how actively involved they were in managing those assets.

In the dissenting opinion for Coombes v. Getz, Justice Stone argued that the majority's decision to uphold a California law prohibiting non-residents from shrimping in state waters was inconsistent with previous rulings on similar issues. He contended that this ruling violated the Privileges and Immunities Clause of Article IV of the Constitution, which guarantees citizens of each state equal access to all privileges and immunities in every other state. According to Justice Stone, there is no substantial reason why residents should have exclusive rights over natural resources within their own states while denying those same rights to non-residents. Furthermore, he believed that such laws could lead to retaliatory measures by other states and disrupt interstate commerce.