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Taxation of Seats on the Stock Exchange, 31 Yale Law Journal 429 (1922)


The prevailing concept of "property" is often rudely tested in taxation

cases. The rules laid down in statutes and decisions have often

been constructed with the idea that property is a physical res-an

object of sensation. As such, property would always have a situs”-


relation in space to other objects of sense. But a chose in action is

also property, although it is not a thing or res-an object of sense.

Our concept of property has shifted; incorporeal rights have become

property. And finally, "property" has ceased to describe any res,

or object of sense, at all, and has become merely a bundle of legal

relations-rights, powers, privileges, immunities. Such is the case

whether these relations affect the consumption and enjoyment of

some particular object of sense or not.

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