In the case of Guaranty Trust Co., Executor, v. Virginia in 1938, the U.S Supreme Court ruled on a dispute regarding inheritance tax laws. The plaintiff was an executor for a New York resident's estate that held bonds secured by real property located in Virginia. After the bondholder's death, Virginia imposed an inheritance tax on these out-of-state securities which were backed by its own land assets. The executor challenged this taxation as unconstitutional under due process and commerce clauses of the Constitution. The court upheld Virginia’s right to impose such taxes with Justice Benjamin Cardozo stating that states have jurisdiction over their own soil and can therefore levy taxes upon it or any interest therein even if owned by non-residents. He further clarified that while interstate commerce may be affected indirectly through such taxation, it does not constitute direct regulation thereof hence doesn't violate federal law. This decision established important precedent concerning state rights to tax interests tied to within-state properties regardless of where owners reside.

In the dissenting opinion for Guaranty Trust Co., Executor, v. Virginia, Justice Benjamin N. Cardozo argued that the majority's decision to allow states to tax intangible property held by non-residents was a violation of due process rights under the Fourteenth Amendment. He contended that this ruling would create an unfair burden on out-of-state entities and could potentially lead to double taxation if other states followed suit. Furthermore, he expressed concern about potential conflicts between state laws and how they might affect interstate commerce or relations between states. In his view, only Congress had the constitutional authority to regulate such matters in order to ensure uniformity across all jurisdictions.