Armour & Co. v. Virginia

Citations

• 246 U.S. 1
• 38 S. Ct. 267
• 62 L. Ed. 547
• 1918 U.S. LEXIS 1515

Syllabus

<p>A law of Virginia (Acts 1915, c. 148, p. 233) imposes a license tax on merchants doing business in the State based on the amount of purchases during the license period, including as purchases all goods, wares and merchandise manufactured by the licensee and sold or offered for sale in the State'; but excludes from its operation manufacturers taxed on capital by the State, who offer for sale at the place of manufacture the goods, wares and merchandise manufactured by them. The Court of Appeals of the State having interpreted this exclusion as open to all, including non-citizens and nonresidents, who manufacture in Virginia, and the license as extending as well to those who manufacture in Virginia and sell the goods at places other than the place of manufacture, as to those who m,anu-facture without and sell within the State. Meld; that the license, tax, as applied, to a New-Jersey corporatioi^tnd as computed on the basis of merchandise manufactured by itNn other States and shipped into Virginia for sale at its agencies there, does not offend the equal protection clause of the Fourteenth Amendment, or abridge the privileges and immunities of the corporation guaranteed by that Amendment- and by Art. IV of the Constitution, or constitute, either inherently or by necessary operation and effect, an unconstitutional burden on interstate commerce.</p>