36 . rmnmnu. nmroarm.
all property within the state, without: reference to the residence of the
owner. (c) The state may provide for the taxation of the personal property of
a non-resident situated within its jurisdiction.(d) An alien may be taxed as
well as a citizen.(e) The right to tax a person results from the protection
afforded to himself, his business, or his property. (f) Personal property of a
non-resident, which has a locus within the state, is taxable.(g) A statute
, taxing " all personal property," means all personal property within the state,
1rrespective of ownership,(h) as a herd of cattle, a flock of sheep, or a stock of
goods.(i) The real estate of a non—resident is taxable where it is located.(j)
Personalty owned by a non-resident is taxable where he resides.(k) A per- ‘
sonal tax cannot be assessed against a non-resident.(Z) Non-residents may be
taxed on property where situated, and on business where carried on.(m) A
statute which provides that non·-residents ‘* doing business" in the state shall
be taxed on sums invested ** in business/’ does not apply to a manufactured
article sent for sale by the agent.(n) The business of a. non-resident carried
on within the state may be taxed.(o) A private banker, for the purposes of
taxation, is to be regarded as resident where the bank is located.(p) Mem-
bers of a partnership are severally taxable where they 1·eside.(q)
Suns or Pnnsoiur. Pnormvrv. Debts due to a non-resident are not prop-
erty of the debtor, and have no situs but the residence of the owner.(r) A
person cannot be assessed on capital invested in another state, or on chattels
upon land in another state.(s) So the personal property of a non-resident is not
taxable at his temporary summer residence within the state.(t) Stocks of a
foreign corporation follow the `situs of the 0wner.(u) Shares of stock
in corporations may be taxed at the place where the business is carried 0n.(o)
Steam-boats which ply between different points on a navigable river may,
under a state statute, be taxed as personal property where the company own-
(c) Arapahoe Co. v. Cutter, 3 Colo. 350. (1) Herriman v. Stowers, 43 Me. 497; Dow v.
(et) Green v. Van Buskirk, 7 Wall. 150; People Sudbury, 5 Metc. 73; St. Paul v. Merritt, 7 Minn.
v. Ins. Co. 29 Cal. 533; Mills v. Thornton, 26 Ill. 258; People v. Sup’rs, 11 N. Y. 563.
200; Rleman v. Shepard, 27 Ind. 288; State v. (m) Corlield v.Corye1l,4 Wash. C. C.380; Pad.
Fnlkenhnrg, 15 N. 1.320; Howell v. State, 3 Gill, elford v. The Mayor, 14 Ga. 438; Pearce v Au.
,14; Blackstone Manut"g Co. v. Blackstone, 13 gusta,37Gz¢.597;Harrison v.Vicksburg,3Smedes
Gray, 488; Leonard v. New Bedford, 16 Gray, 292; ULM. 581; Worth v. Fayetteville, l Winst. 70; State
Hartland v. Church, 47 Me. 169; Desmond v. v.Charleston,2Specrs,623;Shr1verv.Pittsburgb,
Machias,48 Me.478; St. Louis v. Ferry C0. 40 Me. 66 Pa. St. 446. '
580; Hoyt »v. Com’rs, 23 N. Y. 224; People v. Og. (n) Parker Mills v. Com’rs, 23 N. Y. 242.
densburg, 48 N. Y. 390; Wilson v. New York,4 E. (0) Corileld v. Coryell, 4 Wash. C. C. 371; Pad.
D. Smith, 675; Hood’s Estate, 21 Pa. St. 114; elford v. Savannah, 14 Ga. 438; Pearce v. Au.
Maltby v. Reading R. Co. 52 Pa. St. 140; Steere v. gusta, 37   597;H:1rrison v. Vicksburg, 3 Srnedes
Walling, 7 R. 1.317; Catlin v. Hull, 21 Vt. 152. Sa M. 581; State v. Charleston, 2 Speers, 623;
(e) Witherspoon v. Duncan, 4 Wall.210. Shriver v. Pittsburgh, 66 Pa. St. 446; Worth v.
(f) De Pauw v. New Albany. 22 Ind. 204; Bank Fayetteville, 1 Winst. 70.
of U, S. v. State, 12 Smedes Bs M. 456; Eggleston (p) Bates v. Mobile, 46 Ala. 158; Miner v. Fm.
v. Charleston, 1 Const. S. 0.45. donia, 27 N. Y. 155; Gardner, etc., Co. v. Gard-
(g) Arapahoe C0. v. Cutter, 3 C010. 350; Catlin ner, 5 Me. 133.
· v, Hull, 21 Vt. 152; Duer v. Small. 17 How. Pr. » (q) Bemis v. Boston, 14 Allen, 366. See Hood.
201. ley v. Com’rs, 105 Mass. 519.
4 (h) McCutchen v. Rice Co. 2 McCrary, 337; (r) Arapahoe Co. v. Cutter, 3 Colo. 350.
Ogilvie v. Crawford C0. 2 McCrary, 148. (s) People v. Com’rs, 23 N. Y. 224.
(i) Arapahoe Co. v. Cutter, 3 0010. 350. (¢) Phelps v. Thurston, 47 Conn. 477.
(j) Witherspoon v. Duncan, 4 Wall. 210; Jones (u) McKeon v. Northampton Co. 49 Pa. St. 519;
v. Columbus, 25 Ga. 610; Turner v. Burlington, Whitsell v. Northampton Co. Id. 526.
16 Mass. 208. (M Tappan v. Merchant? Nat. Bank, 19 Wall.
(ic) Com. v. Hays, 8 B. Mon._2. 490. _