Charles Evans Hughes, Minnesota v. Blasius — Opinion of the Court
“ But because there is a flow of interstate commerce which is subject to the regulating power of the Congress, it does not necessarily follow that, in the absence of a conflict with the exercise of that power, a state may not lay a nondiscriminatory tax upon property which, although connected with that flow as a general course of business, has come to rest and has acquired a situs within the state. ”
Charles Evans Hughes, Minnesota v. Blasius — Opinion of the Court
“ Thus, the states cannot tax interstate commerce, either by laying the tax upon the business which constitutes such commerce or the privilege of engaging in it, or upon the receipts, as such, derived from it. [2] Similarly, the states may not tax property in transit in interstate commerce. [3] But, by reason of a break in the transit, the property may come to rest within a state and become subject to the power of the state to impose a non-discriminatory property tax. ”
Charles Evans Hughes, Minnesota v. Blasius — Opinion of the Court
“ Where property has come to rest within a state, being held there at the pleasure of the owner, for disposal or use, so that he may dispose of it either within the state, or for shipment elsewhere, as his interest dictates, it is deemed to be a part of the general mass of property within the state and is thus subject to its taxing power. ”
