Charles Evans Hughes

“ The South Carolina Tax Commission also levied a tax upon the transfer of the indebtedness, overruling the claim of the executors that the state of South Carolina had no jurisdiction to impose such a tax, and that the levy of it would constitute a deprivation of property without due process of law in violation of the Fourteenth Amendment of the federal Constitution. ”

“ Open accounts, including credits for cash deposited in bank, fall within this principle, and its application is not defeated by the mere presence of bonds or notes, or other evidences of debt, within a state other than that of the domicile of the owner. ”

“ It is sought to sustain the tax by South Carolina upon the ground that the indebtedness had what is called a 'business situs' in that state, and the state court adverted to this basis for the tax. In Farmers Loan & Trust Company v. ”