lawrence
state
tax
commission
state
mississippi
argued
april
decided
may
wm
watkins
jackson
appellants
lauderdale
jackson
appellee
justice
stone
delivered
opinion
appeal
section
judicial
code
usca
decree
mississippi
upholding
mississippi
income
tax
law
chapter
miss
laws
amended
chapter
miss
code
ann
applied
appellant
assailed
infringing
fourteenth
amendment
federal
constitution
sections
statute
impose
annual
tax
net
income
corporations
individuals
paragraph
section
added
act
laws
miss
ex
provides
term
gross
income
include
income
domestic
corporation
earned
sources
without
state
appellant
citizen
resident
mississippi
brought
present
suit
set
aside
assessment
tax
upon
much
net
income
arose
construction
public
highways
state
tennessee
taxing
statute
challenged
ground
far
imposes
tax
income
derived
wholly
activities
carried
outside
state
deprived
appellant
property
without
due
process
law
exempting
corporations
competitors
tas
income
derived
like
activities
carried
outside
state
denied
equal
protection
laws
obligation
one
domiciled
within
state
pay
taxes
arises
unilateral
action
state
government
exercise
plenary
sovereign
powers
raise
revenue
defray
expenses
government
distribute
burdens
equably
among
enjoy
benefits
hence
domicile
establishes
basis
taxation
enjoyment
privileges
residence
within
state
attendant
right
invoke
protection
laws
inseparable
responsibility
sharing
costs
government
see
fidelity
columbia
trust
louisville
maguire
trefry
kirtland
hotchkiss
shaffer
carter
federal
constitution
imposes
particular
modes
taxation
apart
specific
grant
federal
government
exclusive
power
levy
certain
limited
classes
taxes
regulate
interstate
foreign
commerce
leaves
unrestricted
power
tax
domiciled
within
long
tax
imposed
upon
property
within
state
privileges
enjoyed
palpably
arbitrary
unreasonable
infringe
fourteenth
amendment
kirtland
hotchkiss
supra
taxation
place
domicile
tangibles
located
elsewhere
thought
beyond
jurisdiction
state
union
refrigerator
transit
kentucky
ann
cas
frick
pennsylvania
considerations
applicable
ownership
physical
objects
located
outside
taxing
jurisdiction
led
conclusion
obviously
inapplicable
taxation
intangibles
place
domicile
privileges
may
enjoyed
see
state
tax
foreignheld
bonds
wall
frick
pennsylvania
supra
page
taxation
state
domicile
uniformly
upheld
kirtland
hotchkiss
supra
fidelity
columbia
trust
louisville
supra
blodgett
silberman
maguire
trefry
supra
compare
farmers
loan
trust
minnesota
first
national
bank
boston
maine
present
tax
defined
mississippi
excise
property
tax
hattiesburg
grocery
robertson
miss
knox
gulf
miss
passing
constitutionality
concerned
practical
operation
definition
precise
form
descriptive
words
may
applied
see
educational
films
ward
pacific
johnson
ed
decided
april
shaffer
carter
supra
pages
enough
far
constitutional
power
state
levy
concerned
tax
imposed
mississippi
citizens
reference
receipt
enjoyment
income
derived
conduct
business
regardless
place
carried
tax
apportioned
ability
taxpayer
bear
founded
upon
protection
afforded
recipient
income
state
person
right
receive
income
enjoyment
received
rights
privileges
incident
domicile
state
economic
interest
realized
receipt
income
represented
power
control
bears
direct
legal
relationship
anomalous
say
although
mississippi
may
tax
obligation
pay
appellant
services
rendered
tennessee
see
fidelity
columbia
trust
louisville
supra
farmers
loan
trust
minnesota
supra
still
tax
receipt
income
upon
payment
obligation
find
basis
holding
taxation
income
domicile
recipient
either
within
purview
rule
established
tangibles
located
outside
state
owner
subject
taxation
within
respect
arbitrary
unreasonable
place
outside
constitutional
power
taxation
reserved
state
maguire
trefry
supra
see
fidelity
columbia
trust
louisville
supra
mississippi
found
unnecessary
pass
upon
validity
much
statute
added
amendment
exempted
domestic
corporations
tax
income
derived
activities
outside
state
said
amendment
valid
appellant
complain
invalid
still
subject
tax
since
act
amended
section
laws
remain
full
force
individuals
domestic
corporations
taxed
alike
knox
gulf
supra
constitution
guarantees
rights
immunities
citizen
likewise
insures
privilege
rights
immunities
judicially
declared
protected
judicial
action
properly
invoked
even
though
claimed
constitutional
protection
denied
nonfederal
grounds
province
inquire
whether
decision
state
rests
upon
fair
substantial
basis
unsubstantial
constitutional
obligations
may
thus
avoided
see
ward
love
county
enterprise
irrigation
district
canal
company
fox
river
paper
railroad
commission
upon
one
alternative
assumptions
made
amendment
discriminatory
appellant
constitutional
rights
infringed
tax
levied
upon
state
officers
acting
amendment
refrained
assessing
like
tax
upon
corporate
competitors
see
moines
national
bank
bennett
constitution
exacts
uniform
application
tax
appellant
competitors
constitutional
rights
denied
well
refusal
state
decide
question
erroneous
decision
see
greene
louisville
interurban
et
ann
cas
smith
cahoon
either
case
inequality
complained
left
undisturbed
state
whose
jurisdiction
remove
rightly
invoked
burden
rest
test
validity
amendment
procedure
compel
competitors
pay
tax
earlier
statute
moines
national
bank
bennett
supra
page
see
cumberland
coal
board
revision
therefore
conclude
purported
nonfederal
ground
put
forward
state
refusal
decide
constitutional
question
unsubstantial
illusory
appellant
may
invoke
jurisdiction
decide
question
statute
relieves
domestic
corporations
tax
far
income
derived
activities
carried
outside
state
appellant
thus
compelled
pay
tax
competitors
domestic
corporations
relieved
urged
plainly
arbitrary
infringe
equal
protection
clause
constitutional
requirement
system
taxation
uniform
applied
individuals
corporations
regardless
circumstances
operates
acceptance
contention
relieve
appellant
burden
rests
overcome
presumption
facts
supporting
constitutionality
attaches
legislative
acts
require
assume
state
facts
reasonably
conceived
afford
rational
basis
distinguishing
taxation
purposes
income
individuals
domestic
corporations
derived
business
carried
without
state
lindsley
natural
carbonic
gas
ann
cas
rast
van
deman
lewis
ann
cas
young
hartford
fire
ins
local
conditions
mississippi
neighboring
respect
businesses
like
present
carried
across
state
lines
individuals
corporations
appear
statutory
provisions
question
related
others
permissible
divergence
state
policy
respect
taxation
corporations
individuals
may
effected
shown
see
general
american
tank
car
day
interstate
busses
corporation
blodgett
farmers
mechanics
savings
bank
minnesota
et
say
investigation
fields
close
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
apart
considerations
may
led
present
legislation
integral
part
state
system
taxation
income
corporations
one
affords
rational
basis
distinction
made
fact
state
adopted
generally
policy
avoiding
double
taxation
economic
interest
corporate
income
taxing
either
income
corporation
dividends
stockholders
see
sections
case
corporate
income
dividends
attributable
business
done
outside
state
received
stockholders
domestic
corporations
stockholders
taxed
corporation
held
franklin
carter
sufficient
ground
upholding
statute
oklahoma
assailed
denying
equal
protection
laws
substantially
features
present
statute
see
also
conner
question
presented
thus
differs
raised
quaker
city
cab
pennsylvania
royster
guano
virginia
compare
white
river
lumber
arkansas
equal
protection
clause
require
state
maintain
rigid
rule
equal
taxation
resort
close
distinctions
maintain
precise
scientific
uniformity
possible
differences
tax
burdens
shown
substantial
based
discriminations
shown
arbitrary
capricious
fall
within
constitutional
prohibitions
ohio
oil
conway
southwestern
oil
texas
kentucky
state
board
tax
commissioners
indiana
jackson
affirmed
justice
van
devanter
dissents
much
opinion
concerns
equal
protection
clause
fourteenth
amendment