Harlan F. Stone

“ It is said that the tax computed on the number of nonpar shares at a flat rate may bear little relation to the property and business of the corporation within the state and consequently corporations having like property and business within the state, but with a different nonpar capitalization, may be required to pay a different tax. But this is equally true of corporations having par value stock, even though full value be paid in on its issue. Par value and actual value of issued stock are not synonymous and there is often a wide disparity between them. ”

“ Nor is such a tax to be deemed a denial of equal protection because a different measure or method of computing the tax is applied to corporations having nonpar stock from that applied to corporations having stock of par value. ”

“ Co. v. Harding, 272 U.S. 494, 510, 47 S.C.t. 179, 71 L. Ed. 372, 49 A. L. R. 713, the invalidity of the taxing statute was established by the decision of this court in Air-Way Electric Appliance Corp. v. ”