BRADLEY, J., (with whom concurred FIELD and HARLAN, JJ., dissenting.) I dissent from the judgment of the court in this case, and will state briefly my reasons. I concede that all property, personal as well as real, within a state, and belonging there, may be taxed by the state. Of that there can be no doubt. But where property does not belong in the state, another question arises. It is the question of the jurisdiction of the state over the property. It is stated in the opinion of the court as a fundamental proposition on which the opinion really turns that all personal as well as real property within a state is subject to the laws thereof. I conceive that that proposition is not maintainable as a general and absolute proposition. Among independent nations, it is true, persons and property within the territory of a nation aresubject to its laws, and it is responsible to other ati ons for any injustice it may do to the persons or property of such other nations. This is a rule of international law. But the states of this government are not independent nations. There is such a thing as a constitution of the United States, and there is such a thing as a government of the United States, and there are many things, and many persons, and many articles of property that a state cannot lay the weight of its finger upon, because it would be contrary to the constitution of the United States. Certainly, property merely carried through a state cannot be taxed by the state. Such a tax would be a duty,-which a state cannot impose. If a drove of cattle is driven through Pennsylvania from Illinois to New York for the purpose of being sold in New York, while in Pennsylvania it may be subject to the police regulations of the state, but it is not subject to taxation there. It is not generally subject to the laws of the state, as other property is. So if a train of cars starts at Cincinnati for New York, and passes through Pennsylvania, it may be subject to the police regulations of that state while within it, but it would be repugnant to the constitution of the United States to tax it. We have decided this very question in the Case of State Freight Tax, 15 Wall. 232. The point was directly raised and decided that property on its passage through a state in the course of interstate commerce cannot be taxed by the state, because taxation is incidentally regulation, and a state cannot regulate interstate commerce. The same doctrine was recognized in Coe v. Errol, 116 U.S. 517, 6 Sup. Ct. Rep. 475. And surely a state cannot interfere with the officers of the United States in the performance of their duties, whether acting under the judicial, military, postal, or revenue departments. They are entirely free from state control. So a citizen of the United States, or any other person, in the performance of any duty, or in the exercise of any privilege, under the constitution or laws of the United States is absolutely free from state control in relation to such matters. So that the general proposition that all persons and personal property within a state are subject to the laws of the state, unless materially modified, cannot be true. But when personal property is permanently located within a state for the purpose of ordinary use or sale, then, indeed, it is subject to the laws of the state and to the burdens of taxation, as well when owned by persons residing out of the state as when owned by persons residing in the state. It has then acquired a situs in the state where it is found. A man residing in New York may own a store, a factory, or a mine in Alabama, stocked with goods, utensils, or materials for sale or use in that state. There is no question that the situs of personal property so situated is in the state where it is found, and that it may be subjected to double taxation,-in the state of the owner's residence, as a part of the general mass of his estate; and in the state of its situs. Although this is a consequence which often bears hardly on the owner, yet it is too firmly sanctioned by the law to be disturbed, and no remedy seems to exist but a sense of equity and justice in the legislatures of the several states. The rule would undoubtedly be more just if it made the property taxable, like lands and real estate, only in the place where it is permanently situated. Personal as well as real property may have a situs of its own, independent of the owner's residence, even when employed in interstate or foreign commerce. An office or warehouse connected with a steam-ship line or with a continental railway may be provided with furniture and all the apparatus and appliances usual in such establishments.