University of Missouri Bulletin Law Series

Document Type



In the decision of Union Refrigerator Transit Co. v. Kentucky, the Supreme Court of the United States in 1905 definitely set at rest the proposition that tangible personal property having acquired a permanent situs in another state is not subject to taxation in the state of the owner's domicile. Since that time comparatively little difficulty has been encountered in the taxation of tangibles, though it was not until 1925 that the full scope of this doctrine was applied to inheritance taxation as distinguished from property taxes in the case of Frick v. Pennsylvania. The maxim mobilia sequuntur personaim, having thus been definitely circumscribed with reference to its application to tangibles, remained in its complete vigor as applied to intangibles. Two problems in this connection have given rise to considerable difficulty. First, when is property to be classed as intangible, or, to state it differently, may documentary evidence of property acquire the status of tangibles for purposes of taxation? Second, may intangibles be taxed otherwise than at the domicile of the owner?

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