“ Since all the activities upon which the tax is imposed are carried on in Mississippi, there is no due process objection to the tax. [9] The tax does not discriminate against interstate commerce in favor of competing intrastate commerce of like character. [10] The nature of the subject of taxation makes apportionment unnecessary; there is no attempt to tax interstate activity carried on outside Missi sippi's borders. No other state can repeat the tax. [11] For these reasons the commerce clause does not invalidate this tax. ”

“ This appeal questions the power of Mississippi, as affected by the commerce clause, to impose a tax measured by gross receipts from the operation of a pipe line wholly within the state.
Appellant is a Delaware corporation which has qualified to do business in Mississippi as a foreign corporation. It owns and operates pipe lines which are used to transport oil from lease tanks in various oil fields in Mississippi to loading racks adjacent to railroads elsewhere in the state. [1] From these racks the oil is pumped into railroad tank cars for shipment outside the state. ”

“ There are no refineries in Mississippi. There is no through bill of lading from the point of origin at the fields to the destination outside the state. Appellant ships the oil by rail as agent of the owner on bills of lading showing the owner as shipper, the appellant as agent of the shipper and indicating the destination specified in the shipping orders issue to appellant. Appellant is paid by the producer at the rate per barrel specific in its tariff [2] from the gathering point to the rack and is paid an additional charge for loading the oil in the tank cars. ”