James Clark McReynolds

“ Speaking there of this same statute we did declare:
'The tax in question is, therefore, not only one for the privilege of doing life insurance business within the state, but is in effect a commutation tax, levied by the state in place of all other taxation upon the personal property of the company in the state of Wisconsin.'
But no question was then raised concerning taxation of income derived from United States bonds. The point now presented was not involved.
It cannot be denied (and denial is not attempted) that bonds of the United States are beyond the taxing power of the states. ”

“ It is important to observe that, although a state statute may properly impose a charge which materially affects interstate commerce without so unreasonable burdening it as to become a regulation within the meaning of the Constitution, no state can lay any charge on bonds of the United States. ”

“ The power to tax property necessary to the conduct of interstate commerce has been often upheld, and without doubt the states by apt enactments may tax the ordinary property, franchises or business of their own corporations. ”