Charles Evans Hughes

“ There is a recognized distinction between a non-discriminatory tax upon the property of an agent of government, albeit the property is used in, or has relation to, the business of the agency-where there is only a remote, if any, influence upon the exercise of the functions of government-and a tax which is deemed to impose a direct burden upon the exertion of governmental powers. ”

“ These cases present the question of the validity of ad valorem taxes upon crude oil belonging to petitioner, Indian Territory Illuminating Oil Company, and held by it in its storage tanks in Tulsa County and Payne County, Oklahoma. In each case, the tax was challenged upon the ground that the oil was exempt because in its production petitioner was operating as an instrumentality of the United States. ”

“ Union Pacific Railroad Co., 9 Wall. 579, 590, 19 L.Ed. 792; Union Pac. Railroad Company v. Peniston, 18 Wall. 5, 33, 36, 21 L.Ed. 787; Baltimore Shipbuilding & Dry Dock Co. v. Baltimore, 195 U.S. 375, 382, 25 S.Ct. 50, 49 L.Ed. 242; Choctaw, O. & G.R. Co. v. ”