In the 1943 case Demorest et al. v. City Bank Farmers Trust Co., Trustee, et al., the U.S Supreme Court dealt with a dispute over inheritance tax laws in New York State. The plaintiffs were beneficiaries of a trust established by their late father and contested that they should not be subjected to pay an inheritance tax on income generated from securities held within the trust because these securities were physically located outside of New York state at the time of their father's death. However, both lower courts ruled against them based on previous precedents which stated that intangible personal property (like stocks and bonds) is deemed to be located at the domicile of its owner for taxation purposes regardless of where it is actually situated or where it was created. The Supreme Court upheld these rulings, stating that while there are exceptions to this rule under certain circumstances such as when tangible property has acquired an actual situs elsewhere due to being used in business activities outside its owner’s domicile - those exceptions did not apply here since no evidence suggested any active use or management of said securities outside New York state by either decedent prior his death or trustee afterwards.

The dissenting opinion in the case of Demorest et al. v. City Bank Farmers Trust Co., Trustee, et al., argued that the majority's decision was inconsistent with previous rulings and principles regarding trusts and estates. The dissenters believed that a trust should not be considered as having been created until it has actually received property or assets to manage, which had not occurred at the time of Mrs. Demorest's death in this case. They also disagreed with the majority's interpretation of New York law on future interests, arguing that it did not support their conclusion about when a trust is established for tax purposes. Furthermore, they contended that even if there were ambiguity in state law on this point, federal tax laws should govern how such matters are handled for estate tax purposes.