Oliver Wendell Holmes, Jr.

“ The appellant, pursuing his notion that shares of stock represent an interest in the property of the corporation insists that if taxed at all he should be taxed only in the ratio of the property in the State of the entire property of the corporation; that to tax him for the whole value is to tax property outside of the jurisdiction of the State. But it leads nowhere to call a corporation a fiction. If it is a fiction it is a fiction created by law with intent that it should be acted on as if true. ”

“ It in alleged as a distinct point of objection, though perhaps less earnestly pressed, that appellant's stock was assessed at its full selling price whereas land was taxed at seventy-five per cent of its sale value. There is nothing in the Fourteenth Amendment that requires land and stock to be taxed at the same rate or by the same tests and the Court of Appeals thinks that the Board of Tax Commissioners 'judged that seventy-five per cent of the sale values represented about fairly the cash value of real estate.' Whether this be so or not we see no constitutional ground for complaint. ”