New York Central R. Co. v. Miller,
202 U.S. 584 (1906)

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U.S. Supreme Court

New York Central R. Co. v. Miller, 202 U.S. 584 (1906)

New York Central Railroad Company v. Miller

Nos. 81-82, 586-588

Argued April 9, 1906

Decided May 28, 1906

202 U.S. 584


If the state statute as construed by its highest court is valid under the federal Constitution, this Court is bound by that construction.

The origin remains the permanent situs of personal property notwithstanding its occasional excursions to foreign parts, and a state may tax its own corporations for all their property in the state during the year even if every item should be taken into another state for a period and then brought back.

The taxation of cars, under the New York franchise tax law, belonging to a

Page 202 U. S. 585

New York corporation is not unconstitutional as depriving the owner of its property without due process of law because the cars are at times temporarily absent from the state, it appearing that no cars permanently without the state are taxed.

The facts are stated in the opinion.

Page 202 U. S. 593

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