he decedent's interest in a foreign partnership.

In the course of about two years following the recent Depression, the
Court handed down a group of four decisions which, for the time being at
any rate, placed the stamp of disapproval upon multiple transfer and--by
inference--other multiple taxation of intangibles. Asserting, as it did
in one of these cases, that "practical considerations of wisdom,
convenience and justice alike dictate the desirability of a uniform
general rule confining the jurisdiction to impose death transfer taxes
as to intangibles to the State of the [owner's] domicile; * * *"[521]
the Court, through consistent application of the maxim, _mobilia
sequuntur personam_, proceeded to deny the right of nondomiciliary
States to tax and to reject as inadequate jurisdictional claims of the
latter founded upon such bases as control, benefit, and protection or
situs. During this interval, 1930-1932, multiple transfer taxation of
intangibles came to be viewed, not merely as undesirable, but as so
arbitrary and unreasonable as to be prohibited by the due process
clause.

Beginning, in 1930, with Farmers' Loan and Trust Co. _v._
Minnesota,[522] the Court reversed its former ruling in Blackstone _v._
Miller,[523] in which it had held that the State in which a debtor was
domiciled or a bank located could levy an inheritance tax on the
transfer of the debt or the deposit, notwithstanding that the creditor
had his domicile in a different State. Farmers' Loan and Trust Co. _v._
Minnesota, strictly appraised, was authority simply for the proposition
that jurisdiction over a debtor, in this instance a State which had
issued bonds held by a nonresident creditor, was inadequate to sustain a
tax by that debtor State on the transfer of such securities. The
securities in question, which had never been used by the creditor in any
business in the issuing State, were located in the State in which the
creditor had his domicile, and were deemed to be taxable only in the
latter. In Baldwin _v._ Missouri,[524] a nondomiciliary State was
prevented from applying its inheritance tax to bonds, bank deposits, and
promissory notes, all physically present within its limits and some of
them secured by lands therein, when the owner thereof was domiciled in
another State. A like result, although on this occasion on grounds of
lack of evidence of any "business situs," was reached in Beidler _v._
South Carolina Tax Commission,[525] in which