Stanley Forman Reed

“ Our issue at this point is whether a privilege tax for carrying on a wholly interstate transportation business measured by a fairly apportioned part of gross receipts for carriage in interstate commerce is constitutionally permissible. ”

“ Where the corporate taxpayer conducts intrastate as well as interstate business, a franchise privilege or excise tax on the former is of course permissible. [16] We have frequently upheld such a tax although it was measured by property or receipts which were used in or attributable to interstate business. [17]
The growth of commerce that is carried on in more than one state has brought responsibilities to states other than the one in which the commerce may be said to have originated. ”

“ Control of interstate commerce passed into the hands of Congress and thus welded the Federation into a Nation So long as states are forbidden to impose taxes upon interstate commerce or for the privilege of carrying it on, a toll cannot be exacted from interstate commerce even if a similar tax is borne by local commerce. ”

“ Transportation runs across state lines. All states are called upon to give governmental services for this commerce-service that costs and should be paid for by those who profit from its maintenance. In the absence of congressional direction as to the taxation of interstate commerce, this Court has interpreted the commerce clause to permit state nondiscriminatory taxation for the use of state facilities, upon the property used in interstate commerce, upon production for commerce and upon net proceeds therefrom. ”

“ Incidental dealings with the moving commodity do not break the interstate journey. [8] Recently we have considered the effect of 'split' means of transportation as to whether the transportation was interstate. United States v. Capital Transit Co., 325 U.S. 357, 363, 65 S.Ct. 1176, 1179, 89 L.Ed. 1663. There a traveler went from the District of Columbia via streetcar or bus to a bus terminal and from there by a different bus to nearby Virginia. We held this to be interstate transportation. ”

“ An int rstate journey must have a beginning and an end. Common sense rejects an extension of the journey to the traveler's front door or the producer's farm or factory when no through order for carriage is in effect. The exact limits of interstate commerce in such fringe situations are uncertain. ”

“ Milk Wagon Drivers Union v. Meadowmoor Co., 312 U.S. 287, 294, 61 S.Ct. 552, 555, 85 L.Ed. 836, 132 A.L.R. 1200.↑ Southern Natural Gas Corp. v. Alabama, supra, 301 U.S. at page 154, 57 S.Ct. at page 698, 81 L.Ed. 970; Hooven & Allison Co. v. ”