John Hessin Clarke

“ To require foreign corporations to pay for the privilege of doing business in a state is, of course, a familiar and often approved form of taxation, and in this case the fee imposed is reasonable in amount.
The tax is not imposed directly upon the proceeds of interstate commerce and is not computed upon it. The $235,000 of interstate business of the company is only one of three factors used in estimating or measuring 'the amount of the capital stock represented by property and business transacted in Illinois,' upon which the privilege tax in dispute was computed. ”

“ No formula has yet been devised by which it can be determined in all cases whether or not such a tax is valid, and, applying the repeated declaration of this court, in the cases cited and in many others, that the question is inherently a practical one, depending for its decision on the special facts of each case, we are clear that the tax here involved falls within the excepted class described, even though the business done with residents of states other than Illinois be regarded as interstate. ”

“ United States Express Co. v. Minnesota, 223 U.S. 335, 343, 32 Sup. Ct. 211, 56 L. Ed. 459; Baltic Mining Co. v. Commonwealth of Massachusetts, 231 U.S. 68, 34 Sup. Ct. 15, 58 L. Ed. 127; Kansas City, &c., R. R. Co. v. ”