Joseph McKenna, Billings v. Illinois — Opinion of the Court
“ Human beings are essentially alike, yet some individuals may have attributes or relations not possessed by others, which may constitute them a class. But their classification-indeed, all classification-must primarily depend upon purpose-the problem presented. Science will have one purpose, business another, and legislation still another. ”
Joseph McKenna, Billings v. Illinois — Opinion of the Court
“ Life tenants constitute but a single class, and the incidents of such an estate, the source thereof, the extent, the dominion over and quality of interest in the tenant, is the same irrespective of the ultimate vesting of the remainder. The tax is not upon the property, but is upon the person succeeding to the property.'Undoubtedly, life tenants, regarded simply as persons, may be in legal contemplation the same ”
Joseph McKenna, Billings v. Illinois — Opinion of the Court
“ To dispute that power, however, is not the same thing as to dispute a classification, and yet that there may be dependence,-more freedom of classification in some instances,-has been indicated by the cases. A state cannot regulate interestate commerce, however accurate its classification of objects may be. On the other hand, the taxing power of a state is one of its most extensive powers. It cannot be exercised upon persons grouped according to their complexions. ”
