General American Tank Car Corp. v. Day,
270 U.S. 367 (1926)

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U.S. Supreme Court

General American Tank Car Corp. v. Day, 270 U.S. 367 (1926)

General American Tank Car Corporation v. Day

No. 162

Argued January 21, 1926

Decided March 1, 1926

270 U.S. 367


1. A decision by the highest state court holding a state tax conformable to the requirement of the constitution of the state as regards uniformity of taxation is binding on this Court. P. 270 U. S. 371.

2. A state tax imposed, in lieu of local taxes, on rolling stock which is owned by nonresident corporations having no domicile in the state and is operated over railroads within the state (Act 109, La.Ls.1921) is not objectionable, under the Commerce

Page 270 U. S. 368

Clause, as an attempt to compel nonresident doing interstate business in the state to declare a local domicile, if the amount and method of computing the tax are not in question, and if it does not operate to discriminate in some substantial way between property of such nonresidents and that of residents or domiciled nonresidents. P. 270 U. S. 372.

3. The method of allocating taxes between the state and its political subdivisions is a matter within the competency of the state legislature. P. 270 U. S. 372.

4. Where a state taxing statute which impose a property tax on nonresidents in lieu of local taxes imposed on residents discloses no purpose to discriminate against nonresidents, and in substance does not do so, it is not invalid under the Equal Protection Clause merely because equality in its operation, as compared with local taxation, has not been attained with mathematical exactness. P. 270 U. S. 373.

5. Parties challenging a state tax on nonresidents, upon the ground that it discriminates against them by exceeding the average taxes imposed on residents from which nonresidents are exempt, have the burden of proving such excess. P. 270 U. S. 374.


Appeal from a decree of the district court dismissing the bill in a suit brought by several corporations, not domiciled in Louisiana, to enjoin the appellee, a tax collector for one of the Louisiana parishes, from seizing their property in satisfaction of a tax assessed on their rolling stock operated over railroads within the state.

Page 270 U. S. 370

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