In Salomon et al. v. State Tax Commission of New York, the U.S Supreme Court ruled on a case involving the taxation of securities owned by non-residents but kept in safe deposit boxes within New York state. The plaintiffs, who were executors for an estate that included such securities, argued that this tax violated both due process and equal protection clauses under the Fourteenth Amendment as well as interfering with interstate commerce. However, the court disagreed and upheld New York's right to levy taxes on these assets. The justices reasoned that since these physical properties (securities) were located within its jurisdictional boundaries, it was reasonable for them to be subject to local taxation regardless of their owner’s residency status. They also dismissed claims about violation of equal protection clause stating there was no discrimination involved because all owners of property physically present in NY are taxed equally irrespective if they are residents or not. This decision reinforced states' rights over tangible personal property situated within their borders while ensuring fair treatment between resident and non-resident taxpayers.

In the dissenting opinion for Salomon et al. v. State Tax Commission of New York, Justice Holmes argued that the majority's decision was inconsistent with previous rulings and principles of federalism. He contended that a state has the right to tax its residents on their entire net income, even if some of it is derived from sources outside the state boundaries. The fact that another state might also have a claim to tax part of this income does not invalidate or limit this right in any way according to him. Furthermore, he pointed out that there were no constitutional provisions prohibiting double taxation and hence states should be free to impose taxes as they see fit unless Congress intervenes by law.