The Supreme Court case Rhode Island Hospital Trust Company, Executor of George Briggs, Deceased v. Rufus A. Doughton, Commissioner of Revenue of North Carolina in 1925 revolved around the issue of inheritance tax on intangible personal property owned by a non-resident decedent. The plaintiff was the executor for George Briggs' estate and argued that North Carolina had no jurisdiction to impose an inheritance tax on shares held by Mr. Briggs in two corporations incorporated under its laws because he was not a resident at his time of death but rather lived in Rhode Island where these assets were located physically as well as legally (in terms of ownership). However, the court ruled against this argument stating that it is within a state's right to levy taxes upon transfer or succession to corporate stock belonging to non-residents if those corporations are domiciled within their borders regardless where the owner resides or where physical certificates are kept.

In the dissenting opinion for Rhode Island Hospital Trust Company v. Rufus A. Doughton, it was argued that North Carolina had no jurisdiction to tax property located outside its borders and owned by a non-resident decedent. The dissenting justices contended that the majority's decision violated principles of federalism and state sovereignty by allowing one state to impose taxes on property situated in another state without any substantial connection or nexus between the taxing authority and the taxed entity or individual. They further asserted that this ruling could lead to multiple taxation of the same property by different states, creating an unfair burden on interstate commerce and investment. Therefore, they believed North Carolina’s imposition of inheritance tax over out-of-state securities held in trust for a resident beneficiary was unconstitutional.