In Mellon, Director General v. Goodyear, Administrator (1927), the United States Supreme Court ruled on a case involving an inheritance tax dispute. The decedent was a resident of Pennsylvania and owned stocks in two corporations based in New Jersey at the time of his death. The state of Pennsylvania imposed an inheritance tax on these stocks which were challenged by the administrator of the estate as unconstitutional under due process clause since they were not physically present within Pennsylvania's jurisdiction but rather located where incorporated i.e., New Jersey. The Supreme Court upheld that states have authority to levy taxes on intangible properties such as corporate stock even if those corporations are out-of-state entities, provided that there is sufficient connection between them and taxing state - here being decedent’s domicile or residence status in Pennsylvania. This decision affirmed that taxation power extends beyond physical boundaries and can encompass intangible assets linked to its residents.

The dissenting opinion in the case of Mellon v. Goodyear, 1927, argued that the majority's decision to allow a tax refund claim from an estate was incorrect because it contradicted established legal principles and precedent. The dissent believed that the statute of limitations should have prevented such a claim since it had expired before any action was taken by the administrator of the estate. They also disagreed with allowing an exception for this particular case as they felt it would set a dangerous precedent for future cases where taxpayers could potentially manipulate their circumstances to avoid paying taxes or receive refunds after deadlines had passed. Furthermore, they expressed concern about potential financial implications on government revenue if such claims were allowed outside statutory time limits.