The transfer or succession of real property and tangible personal property is taxable by the state where it is located irrespective of the domicile of the decedent, and the transfer or succession of intangible personal property maybe taxed by the state where the decedent was domiciled at the time of his death. It becomes clear then that the state must establish the domicile of the decedent at the time of his death in order to impose an inheritance tax on the transmission or right of transmission of the intangible personal property. The problem arises in those cases where a decedent who had a place of abode in more than one state, or had performed certain acts in more than one state which independent of his actual intention respecting his domicile might be taken to indicate that he intended to become domiciled in such states had not made his "domicile" or "legal residence" unambiguous, in which instance more than one state may be successful in prevailing over the decedent's estate in a claim involving inheritance taxes in connection with his intangible personal property, thus burdening the estate with multiple taxation upon the transfer of such property.
Note, Florida Affords the Ohio Resident Relief from the Problem of Multiple Inheritance Taxation, 3 Clev.-Marshall L. Rev. 65 (1954)