taxable situs
Definitions from Case Law · United States Supreme Court
Definitions from Case Law
From 280 U.S. 83 - Safe Deposit & Trust Co. v. Virginia · 1929Most cited · 256 citing opinions
Intangible personal property may acquire a taxable situs where permanently located, employed and protected.
How the Supreme Court has restated “taxable situs”
Each Supreme Court definition of “taxable situs,” sized by how often later courts cited it. “Change” is measured by wording overlap with earlier definitions — a rough signal, not a semantic judgment.
How often courts cite the cases defining “taxable situs”
Court decisions citing the 4 opinions that defined “taxable situs” — 732 in all, by decade. Counts are citations to the defining cases as a whole, not verified uses of the term. The dip in the most recent years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the latest years.
All 4 definitions, chronological · 1907–1933
- 1907·205 U.S. 395 - Metropolitan Life Insurance Company of New York v. City of New Orleans[p9]· cited 183×ORIGINAL
Persons are not permitted to avail themselves, for their own benefit, of the laws of a state in the conduct of business within its limits, and then to escape their due contribution to the public need, through action of this sort, whether taken for convenience or by design.
credits in business
Generally speaking, intangible property in the nature of a debt may be regarded, for the purposes of taxation, as situated at the domicil of the creditor and within the jurisdiction of the state where he has such domicil.
intangible debts
The basis of the jurisdiction is the habitual employment of the property within the state. By virtue of that employment the property should bear its fair share of the burdens of taxation to which other property within the state is subject.