the Court ruled that a
State, upon the death of a nonresident creditor, may not apply its
inheritance tax to a debt [open account] owned by one of its domestic
corporations. Finally, in First National Bank _v._ Maine,[526] which has
since been overruled in State Tax Commission _v._ Aldrich,[527] the
Court declared that only the State in which the owner of corporate stock
died domiciled was empowered to tax the succession to the shares by will
or inheritance and that the State in which the issuing corporation was
domiciled could not do so.

Without expressly overruling more than one of these four cases
condemning multiple succession taxation of intangibles, the Court,
beginning with Curry _v._ McCanless[528] in 1939, announced a departure
from the "doctrine, of recent origin, that the Fourteenth Amendment
precludes the taxation of any interest in the same intangible in more
than one State * * *." Taking cognizance of the fact that this doctrine
had never been extended to the field of income taxation or consistently
applied in the field of property taxation, where the concepts of
business situs as well as of domiciliary situs had been utilized to
sustain double taxation, especially in connection with shares of
corporate stock, the Court declared that a correct interpretation of
constitutional requirements would dictate the following conclusions:
"From the beginning of our constitutional system control over the person
at the place of his domicile and his duty there, common to all citizens,
to contribute to the support of government have been deemed to afford an
adequate constitutional basis for imposing on him a tax on the use and
enjoyment of rights in intangibles measured by their value. * * * But
when the taxpayer extends his activities with respect to his
intangibles, so as to avail himself of the protection and benefit of the
laws of another State, in such a way as to bring his person or * * *
[his intangibles] within the reach of the tax gatherer there, the reason
for a single place of taxation no longer obtains, * * * [However], the
State of domicile is not deprived, by the taxpayer's activities
elsewhere, of its constitutional jurisdiction to tax." In accordance
with this line of reasoning, Tennessee, where a decedent died domiciled,
and Alabama, where a trustee, by conveyance from said decedent, held
securities on specific trusts, were both deemed competent to impose a
tax on the transfer of these securities pass