United States Supreme Court Cases & Opinions

U.S. Supreme Court

Puget Sound Stevedoring Co. v. State Tax Comm'n, 302 U.S. 90 (1937)

Puget Sound Stevedoring Co. v. State Tax Commission

No. 68

Argued October 13, 14, 1937

Decided November 8, 1937

302 U.S. 90

Syllabus

1. The business of a stevedoring corporation, acting as an independent contractor, insofar as it consists of the unloading or discharge of cargoes of vessels engaged in interstate or foreign commerce by longshoremen subject to its own direction and control, is interstate or foreign commerce, and the privilege of doing it cannot be taxed by the State. P. 302 U. S. 92.

2. Insofar as the business of a stevedoring corporation consists of supplying longshoremen to shipowners or masters without directing or controlling the work of loading or unloading, it is not interstate or foreign commerce, but rather a local business, and subject, like such business generally, to taxation by the State. P. 302 U. S. 94.

189 Wash. 131, 63 P.2d 532, modified.

Appeal from a judgment affirming the dismissal of a suit to enjoin collection of a tax on the business of the appellant measured by gross receipts.

Page 302 U. S. 91