In the case of Stickney v. Kelsey, Comptroller of the State of New York, 1907, the U.S. Supreme Court ruled on a dispute involving inheritance tax law in New York state. The plaintiff was an executor for an estate that included stocks and bonds from corporations outside of New York but held by a resident at their death. The defendant argued these assets were subject to taxation under state law because they were owned by a resident at their time of death; however, the plaintiff contended that since these securities weren't physically present in NY when taxed or seized for nonpayment thereof - they couldn't be subjected to such taxes according to due process clause (14th Amendment). In its decision, the court sided with Stickney stating that intangible personal property like stocks/bonds can only be taxed where it's located rather than where owner resides/dies as per constitutional principles regarding jurisdiction over property & persons.

The dissenting opinion in the case of Stickney v. Kelsey, Comptroller of the State of New York, argued that the majority's decision was inconsistent with previous rulings and violated principles of equity. The dissent pointed out that prior cases had established a clear rule: when a state grants tax exemptions to corporations as part of their charters, those exemptions cannot be revoked without violating constitutional protections against impairing contracts. In this case, however, the court upheld New York's right to impose taxes on corporate franchises despite such an exemption in its charter. The dissent contended that this ruling undermined contractual obligations and could discourage future business investments due to uncertainty about whether granted privileges would be respected by courts.