Oliver Wendell Holmes, Jr.

“ Probably the Constitution does not go further than to require one tax on all attainable sources of value, even if it permits more. People ex rel. Burke v. Badlam, 57 Cal. 594, 601. But it certainly seems intended to tax once, at least, all property which can be come at in any way. San Francisco v. Fry, 63 Cal. 470. A tax in another state is no tax for the purposes of the state of Georgia. ”

“ The distinction intended between stock in corporations of which the property is taxed by the state and that in corporations otherwise untaxed is emphasized by the thirty-third question: 'How many shares of stocks did you own, . . . issued by corporations within this state, the capital stock of which or the property of which is not returned by such corporation for taxation?' We think the distinction consistent with the Constitution, if not required by it, as held in People ex rel. ”

“ And, as manifestly the clearest right to tax belongs to the state where the railroad has its tracks, every principle of justice and patriotism would require the same abstinence from taxing stocks of the railroads of neighboring states that is practised with regard to those of the taxing state-in this case Georgia-itself. ”