“ Justice White, speaking for this court, said that 'under our constitutional system both the national and state governments, moving in their respective orbits, have a common authority to tax many and diverse objects,' and he further pointed out that the transfer of property on death 'is a usual subject of taxation' and one which falls within that common authority. ”

“ If Pennsylvania could tax according to such a standard, other states could. It would mean, as applied to the Frick estate, that Pennsylvania, New York, and Massachusetts could each impose a tax based on the value of the entire estate, although severally having jurisdiction of only parts of it. Without question each state had power to tax the transfer of so much of the estate as was under its jurisdiction, and also had some discretion in respect of the rate ”

“ The Pennsylvania statute provides that where a person domiciled in that state dies seised or possessed of property, real or personal, a tax shall be laid on the transfer of the property from him by will or intestate laws, whether the property be in that state or elsewhere ”

“ Pennsylvania, 141 U.S. 18, 22, 11 S.C.t. 876, 877 (35 L. Ed. 613) , where this court held the actual situs of tangible personalty rather than the domicile of its owner to be the true test of jurisdiction and of power to tax, it was said:
'No general principles of law are better settled, or more fundamental, than that the legislative power of every state extends to all property within its borders, and that only so far as the comity of that state allows can such property be affected by the law of any other state. ”

“ The next question relates to the provision which requires that, in computing the value of the estate for the purpose of fixing the amount of the tax, stocks in corporations of other states shall be included at their full value without any deduction for transfer taxes paid to those states in respect of the same stocks. ”

“ The old rule expressed in the maxim mobilia sequentur personam, by which personal property was regarded as subject to the law of the owner's domicile, grew up in the Middle Ages, when movable property consisted chiefly of gold and jewels, which could be easily carried by the owner from place to place, or secreted in spots known only to himself. ”

“ Day, 266 U.S. 71, 81, 45 S.C.t. 12, 69 L. Ed. 169; Wallace v. Hines, 253 U.S. 66, 69, 40 S.C.t. 435, 64 L. Ed. 782; Louisville & Jeffersonville Ferry Co. v. Kentucky, 188 U.S. 385, 395, 23 S.C.t. 463, 47 L. Ed. 513. ”

“ Kelly, 16 Wall. 610, 630, 21 L. Ed. 430; Kerr v. Moon, 9 Wheat. 565, 571, 6 L. Ed. 161; Blackstone v. Miller, 188 U.S. 189, 204, 23 S.C.t. 277, 47 L. Ed. 439; Bullen v. Wisconsin, 240 U.S. 625, 631, 36 S.C.t. 473, 60 L. Ed. 830; Bank of Augusta v. Earle, 13 Pet. 519, 589, 10 L. Ed. 274; Hilton v. Guyot, 159 U.S. 113, 163, 166, 16 S.C.t. 139, 40 L. Ed. 95.
The Pennsylvania statute is a tax law, not an escheat law. ”