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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 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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