William R. Day

“ It is true that the statute also embraces personal property. Used in this connection, personal property undoubtedly refers to such as is lawfully localized within the district, and there held and enjoyed, and thus made subject to the court's jurisdiction to clear its title from clouds and liens, notwithstanding personal service within the district cannot be obtained upon those setting up adverse interests. It is the presence of property real or personal within the district which confers the limited jurisdiction conferred in section 57 upon the District Court. ”

“ With these facts beyond dispute, did section 57 of the Judicial Code, authorizing service in Mississippi, call upon the respondent to answer in the District Court in New York, where the notes were physically held, and there litigate the controversy which had arisen concerning them? ”

“ Ct. 524, 63 L. Ed. 1042, this court sustained a federal tax upon the income from stock, bonds, and mortgages owned by alien nonresidents, but in the hands of an agent in this county, with full authority over them. In that case, as in the Wheeler Case, the previous decisions in this court were cited, which have held that notes, bonds, and mortgages may acquire a situs at a place other than the domicile of the owner, and be reached and taxed as localized property by the taxing authority. ”