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The U.S. Supreme Court case Farmers Loan & Trust Company, Executor v. Minnesota in 1929 revolved around the issue of double taxation and the violation of due process rights under the Fourteenth Amendment. The Farmers Loan & Trust Company, as executor of a New York resident's estate that held bonds issued by a Minnesota corporation, challenged an inheritance tax imposed by Minnesota on these out-of-state securities. The company argued this constituted double taxation because New York had already taxed them as intangible personal property located within its jurisdiction. However, the court ruled against Farmers Loan & Trust Company stating that both states could legally impose taxes without violating due process rights since each state provided benefits and protections to those assets within their respective jurisdictions.
In the dissenting opinion for The Farmers Loan & Trust Company, Executor v. Minnesota case in 1929, Justice Stone argued that the tax imposed by Minnesota on a non-resident's estate was unconstitutional because it violated due process rights under the Fourteenth Amendment. He contended that since the deceased had no property or business operations within Minnesota at his time of death, there was no jurisdictional basis for imposing such a tax. Furthermore, he pointed out that this kind of taxation could lead to multiple states claiming taxes from one estate which would be unfair and burdensome. Thus, according to him, an individual state should not have power over properties located outside its boundaries as it goes against principles of fairness and justice inherent in constitutional law.