Pierce Butler

“ Many corporations subject to the tax do only the latter. Others do both. The basis of the tax imposed on members of the class first mentioned is net income from intrastate business, while the basis of that exacted from members of the other class is net income from all business. The act imposes no tax on corporations engaged exclusively in interstate and foreign business.
The differences portrayed in the argument of appellants do not deny them equal protection of the laws. The measure of the tax is the total net income attributable to California ”

“ The California Bank and Franchise Tax Act declares: Every business corporation, with exceptions not here material, 'shall annually pay to the state, for the privilege of exercising its corporate franchises within this state, a tax according to or measured by its net income' to be computed at the rate of 4 per cent. ”

“ And net income justly attributable to all classes of business done within the state may be used as the measure of a tax imposed to pay the state for the use therein of the corporate franchises granted by it. ”