In the case of Massachusetts v. New York et al., 1925, the Supreme Court ruled on a dispute between states over inheritance taxes. The controversy arose when a resident of Massachusetts died, leaving property in both Massachusetts and New York. Both states sought to impose their respective inheritance tax laws on the entire estate. The state of Massachusetts filed suit against New York, arguing that it had exclusive jurisdiction to tax all personal property owned by its residents at death regardless of where it was located. The Supreme Court held that each state could only levy an inheritance tax on properties physically within its borders at the time of death; therefore, neither state could claim exclusive rights to tax all assets in this situation. This decision established important principles regarding interstate taxation and jurisdictional boundaries for taxing purposes.

In the dissenting opinion for Massachusetts v. New York et al., Justice Holmes argued that the Supreme Court should not have jurisdiction over this case, as it was essentially a political matter rather than a legal one. He believed that the issue at hand - whether or not Congress had exceeded its constitutional authority by approving an interstate compact without requiring ratification by all affected states - was something to be decided through political processes and negotiations between states, rather than through judicial intervention. Furthermore, he contended that even if the court did have jurisdiction, Massachusetts' claim lacked merit because there was no evidence of actual harm or injury resulting from Congress' actions. Therefore, in his view, there were insufficient grounds for granting relief to Massachusetts under federal law.