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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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