In the 1955 case Wisconsin v. Tennessee, the U.S. Supreme Court was asked to settle a dispute between two states over their respective tax laws. The state of Wisconsin had imposed an inheritance tax on shares of stock in a corporation that were owned by a resident of Tennessee at the time of his death. However, under Tennessee law, these shares were not subject to taxation because they represented intangible personal property located outside the state's jurisdiction. The Supreme Court ruled in favor of Wisconsin and upheld its right to impose an inheritance tax on this out-of-state property. In reaching its decision, it noted that while states generally cannot impose taxes on property located beyond their borders, there are exceptions when it comes to intangible assets like stocks and bonds. This is because such assets do not have a physical location and can be considered as being present wherever their owner resides or does business - even if this happens across state lines.

The dissenting opinion in the case of Wisconsin v. Tennessee argued that the Supreme Court should not have jurisdiction over this dispute between states about apportionment of tax revenues from a multi-state corporation. The dissenting justices believed that such matters were better left to negotiation and agreement between individual states, rather than being decided by federal courts. They also expressed concern about the potential for an increase in litigation if more disputes like this one were brought before the court, which could lead to inconsistent or contradictory rulings on similar issues. Furthermore, they questioned whether it was appropriate for a court to make decisions involving complex economic calculations and policy considerations typically handled by legislative bodies or administrative agencies.