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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 physically res - an object of sensation. As such, property would always have a "situs" - a 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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