In the 1913 case Wheeler v. Sohmer, the Supreme Court of the United States ruled on a dispute involving inheritance tax law in New York State. The plaintiff, Wheeler, was an executor for an estate that included stocks and bonds from corporations outside of New York state. The defendant, Sohmer as Comptroller of New York State, sought to impose taxes on these out-of-state assets under a recently enacted state law which taxed all property within its jurisdiction including intangible personal properties like stocks and bonds regardless where they were physically located or incorporated if their owner lived in NY at death. Wheeler argued this violated due process rights by taxing property beyond its jurisdictional reach. The Supreme Court upheld the constitutionality of such taxation with Justice Oliver Wendell Holmes writing for majority stating that while physical presence is necessary for tangible properties to be subject to local taxation; it's not required when dealing with intangibles like securities because ownership resides wherever owner does thus making them taxable by his/her domicile state upon death even if those companies are incorporated elsewhere.

In the dissenting opinion for Wheeler v. Sohmer, Justice Holmes argued that the majority's decision was inconsistent with previous rulings of the Court and violated principles of federalism. He contended that it was not within the purview of the Supreme Court to interfere in state taxation matters unless there is a clear violation of constitutional rights, which he did not believe existed in this case. He also pointed out that New York State had a legitimate interest in taxing corporations operating within its borders and suggested that any perceived unfairness should be addressed by state lawmakers rather than federal courts. Furthermore, he disagreed with the majority's interpretation of due process rights under Fourteenth Amendment as applied to corporate entities.