We have seen that the right of a State to tax depends upon its jurisdiction over the object taxed, and that this jurisdiction is obtained by either actual or constructive presence of the object within the State's territorial limits. This constructive presence applies to personal property and depends upon the principle mobilia sequuntur personam. As to personal property it is thus possible that it may actually Be in one State and be there taxed, and constructively in another State and there also taxed. The fact that one State has exercised its jurisdiction with reference to a matter, whether of taxation or otherwise, clearly can impose no obligation upon another State not to exercise such jurisdiction as it may have. This the Supreme Court of the United Stat?s has repeatedly recognized. In Coe v. Errol67 the court say: "If the owner of personal property resides within a State which taxes him for that property as part of his general estate attached to his person, this action of the latter State does not in the least corporation, and all trades and avocations by which the citizens acquire a livelihood, may be taxed by a state for the support of a state government.' State Freight Tax Case (Philadelphia & R. El Co. v. Pennsylvania). 15 Wall. 232; 21 L. ed. 146; State Tax on Gross Receipts (Philadelphia & R. R. Co. v. Pennsylvania), 15 Wall. 284; 21 L. ed. 164."

66 199 U. S. 1; 25 Sup. Ct. Rep. 705; 50 L. ed. 65.

67 116 U. S. 517; 6 Sup. Ct. Rep. 475; 29 L. ed. 715.

Constitutional Limitations Upon Taxing Powers. 9G9 affect the right of the State in which the property is situated to tax it also." And in Blackstone v. Miller68 the court say: "No doubt this power on the part of two States to tax on different and more or less inconsistent principles leads to some hardship. It may be regretted, also, that one and the same State should be seen taxing on the one hand according to the fact of power, and on the other, at the same time, according- to the fiction that, in successions after death, mobilia sequuntur personam and domicile governs the whole. But these inconsistencies infringe no rule of constitutional law." 69

The double taxation of a piece of property by the same State is, however, forbidden not only by the several constitutions of most of the States, but by the Fourteenth Amendment

68 188 U. S. 189; 23 Sup. Ct. Rep. 277; 47 L. ed. 439.

69 Citing Coe v. Errol, 116 U. S. 517; 0 Sup. Ct Rep. 475; 29 L. ed. 715; Knowlton v. Moore, 178 U. S. 41; 20 Sup. Ct. Rep. 747; 44 L. ed. 969. See also Kidd v. Alabama, 188 U. S. 730; 23 Sup. Ct. Rep. 401; 47 L. ed. 669.