lehnhausen
lake
shore
auto
parts
argued
january
decided
february
together
barrett
county
clerk
cook
county
illinois
et
al
shapiro
et
also
certiorari
illinois
constitutional
provision
subjecting
corporations
similar
entities
individuals
ad
valorem
taxes
personalty
comports
equal
protection
requirements
accorded
wide
latitude
making
classifications
drawing
lines
judgment
produce
reasonable
taxation
systems
quaker
city
cab
pennsylvania
disapproved
pp
reversed
douglas
delivered
opinion
unanimous
william
scott
attorney
general
illinois
argued
cause
petitioner
briefs
jayne
carr
assistant
attorney
general
aubrey
kaplan
argued
cause
filed
brief
petitioners
arnold
flamm
argued
cause
respondents
brief
arthur
susman
louis
biro
argued
cause
respondents
filed
brief
corporation
respondents
weil
sons
et
al
gust
dickett
filed
brief
respondents
shapiro
et
al
edward
berman
eugene
sherman
lewis
schlifkin
filed
brief
proprietor
respondents
herman
dba
spot
et
al
fn
richard
ogilvie
governor
illinois
filed
brief
amicus
curiae
urging
reversal
louis
ancel
stewart
diamond
samuel
witwer
filed
brief
proviso
township
high
school
district
et
al
amici
curiae
urging
affirmance
cases
william
dillon
filed
brief
members
corporate
fiduciaries
association
illinois
amici
curiae
cases
justice
douglas
delivered
opinion
people
illinois
amended
constitution
adding
art
become
effective
january
reading
notwithstanding
provision
constitution
taxation
personal
property
valuation
prohibited
individuals
amendment
abolish
personal
property
tax
valuation
levied
individuals
affect
tax
levied
corporations
entities
considered
law
individuals
amendment
achieve
result
adding
new
article
constitution
article
thus
setting
aside
existing
provisions
article
ix
section
require
taxation
valuation
forms
property
real
personal
owned
individuals
corporations
shapiro
individuals
also
brought
suit
alleging
natural
persons
personal
property
one
family
one
sole
proprietor
business
one
partnership
different
trial
judge
entered
order
cases
dismissing
complaints
except
shapiro
members
class
trial
judge
held
provisions
illinois
law
imposing
personal
property
taxes
property
owned
corporations
unaffected
art
line
statement
ballot
quoted
respondents
cases
appealed
illinois
held
art
affect
forms
real
personal
property
taxes
personal
property
taxes
individuals
construed
mean
ad
valorem
taxation
personal
property
owned
natural
person
two
natural
persons
joint
tenants
tenants
common
construed
illinois
held
tax
violated
equal
protection
clause
fourteenth
amendment
one
justice
dissenting
cases
writs
certiorari
granted
equal
protection
clause
mean
state
may
draw
lines
treat
one
class
individuals
entities
differently
others
test
whether
difference
treatment
invidious
discrimination
harper
virginia
board
elections
taxation
concerned
specific
federal
right
apart
equal
protection
imperiled
large
leeway
making
classifications
drawing
lines
judgment
produce
reasonable
systems
taxation
stated
allied
stores
ohio
bowers
wide
discretion
laying
taxes
dealing
proper
domestic
concerns
trenching
upon
prerogatives
national
government
violating
guaranties
federal
constitution
attribute
sovereign
powers
devising
fiscal
systems
ensure
revenue
foster
local
interests
course
exercise
taxing
power
subject
requirements
equal
protection
clause
fourteenth
amendment
clause
imposes
iron
rule
equality
prohibiting
flexibility
variety
appropriate
reasonable
schemes
state
taxation
state
may
impose
different
specific
taxes
upon
different
trades
professions
may
vary
rate
excise
upon
various
products
required
resort
close
distinctions
maintain
precise
scientific
uniformity
reference
composition
use
value
say
investigation
fields
disclose
basis
legislation
lead
reasonable
men
conclude
ground
difference
made
existence
unchallenged
differences
taxation
incomes
individuals
corporations
every
federal
revenue
act
since
adoption
sixteenth
amendment
demonstrates
may
usually
important
difference
degree
business
done
corporations
done
individuals
see
reason
larger
business
may
taxed
small
ones
disregarded
think
immaterial
exceptions
found
general
rule
furthermore
state
desired
discourage
form
activity
corporate
form
expressed
desire
special
tax
think
nothing
fourteenth
amendment
prevent
said
even
principles
fourteenth
amendment
applicable
present
case
substantial
difference
carrying
business
corporations
taxed
business
conducted
private
firm
individual
thing
taxed
mere
dealing
merchandise
actual
transactions
may
whether
conducted
individuals
corporations
tax
laid
upon
privileges
exist
conducting
business
advantages
inhere
corporate
capacity
taxed
enjoyed
private
firms
individuals
advantages
obvious
led
formation
companies
nearly
branches
trade
continuity
business
without
interruption
death
dissolution
transfer
property
interests
disposition
shares
stock
advantages
business
controlled
managed
corporate
directors
general
absence
individual
liability
things
inhere
advantages
business
thus
conducted
exist
business
conducted
private
individuals
partnerships
distinctive
privilege
subject
taxation
mere
buying
selling
handling
goods
may
whether
done
corporations
individuals
rapid
transit
new
york
excise
tax
levied
every
utility
business
units
sustaining
tax
claim
lack
equal
protection
said
since
carriers
utilities
right
eminent
domain
use
public
property
special
franchises
public
contracts
many
points
distinction
businesses
including
relative
freedom
competition
especially
significant
increasing
density
population
municipal
expansion
public
service
organizations
valid
ground
virtue
equal
protection
clause
object
separate
treatment
related
distinctions
approval
treatment
separateness
distinguishes
public
service
corporations
others
leads
us
conclude
present
cases
making
corporations
like
entities
individuals
liable
ad
valorem
taxes
personal
property
transcend
requirements
equal
protection
madden
kentucky
state
laid
ad
valorem
tax
per
deposits
banks
outside
state
per
deposits
within
state
classification
sustained
charge
invidious
discrimination
noting
taxation
even
fields
legislatures
possess
greatest
freedom
classification
presumption
constitutionality
overcome
explicit
demonstration
classification
hostile
oppressive
discrimination
particular
persons
classes
ibid
added
burden
one
attacking
legislative
arrangement
negative
every
conceivable
basis
might
support
ibid
idea
elaborated
thus
carmichael
southern
coal
sustaining
unemployment
tax
employers
said
state
legislature
enactment
laws
widest
possible
latitude
within
limits
constitution
nature
case
record
complete
catalogue
considerations
move
members
enact
laws
absence
record
courts
assume
action
capricious
informed
acquaintance
local
conditions
legislation
applied
aware
facts
afford
reasonable
basis
action
faithful
adherence
guiding
principle
judicial
review
legislation
possible
preserve
legislative
branch
rightful
independence
ability
function
strike
tax
discriminatory
substituted
judgment
facts
dimly
aware
legislative
judgment
reflects
vivid
reaction
pressing
fiscal
problems
quaker
city
cab
pennsylvania
relic
bygone
era
follow
stay
within
narrow
confines
judicial
review
important
part
constitutional
tradition
reversed
footnotes
result
either
reverse
directions
dismiss
complaints
affirm
judgment
dismissed
complaints
two
cases
heard
illinois
along
petition
file
original
suit
one
maynard
owned
nonbusiness
personal
property
three
school
districts
petition
dismissed
classic
examples
taxes
discriminated
newspapers
struck
first
amendment
grosjean
american
press
discriminated
interstate
commerce
see
pipe
line
calvert
required
licenses
engage
interstate
commerce
see
bolling
sharpe
decided
may
held
federal
discrimination
case
racial
nature
may
arbitrary
violative
due
process
term
used
fifth
amendment
atlantic
pacific
tea
grosjean
state
classified
chain
stores
purposes
chain
store
tax
according
number
stores
inside
outside
state
sustained
tax
saying
statute
bears
equally
upon
fall
class
satisfies
guaranty
equal
protection
carmichael
southern
coal
state
laid
unemployment
tax
employers
excluding
inter
alia
agriculture
domestic
service
crews
vessels
navigable
waters
eleemosynary
institutions
sustained
tax
saying
repeatedly
held
inequalities
result
singling
one
particular
class
taxation
exemption
infringe
constitutional
limitation
added
legislature
bound
tax
every
member
class
none
may
make
distinctions
degree
rational
basis
subjected
judicial
scrutiny
must
presumed
rest
basis
conceivable
state
facts
support
ibid
note
supra