David Josiah Brewer

“ The facts being settled, the only question is one of law. Can Virginia legally subject these vessels to state taxation? The general rule is that tangible personal property is subject to taxation by the state in which it is, no matter where the domicil of the owner may be. ”

“ Of course, if the enrolment does not exempt vessels from taxation as other personal property, the place of enrolment, whether within or without the state in which the property is actually situated, is immaterial, for other like property is taxable at its actual situs. ”

“ Our conclusion is that where vessels though engaged in interstate commerce, are employed in such commerce wholly within the limits of a state, they are subject to taxation in that state, although they may have been registered or enrolled at a port outside its limits. The conclusion, therefore, reached by the Court of Appeals of Virginia was right, and its judgment is affirmed.
Notes
This work is in the public domain in the United States because it is a work of the United States federal government (see 17 U.S.C. 105) . ”