Selliger v. Kentucky Ex Rel. Alexander

Citations

• 213 U.S. 200
• 29 S. Ct. 449
• 53 L. Ed. 761
• 1909 U.S. LEXIS 1867

Syllabus

<p>Where there is nothing in the record on which to base them this court cannot indulge in presumptions as to which of several possible forms a transaction may have' taken.</p> <p>Where goods are exempt from the taxing power of the State under the Constitution of the United States because-not within the State, the protection of the Constitution extends to warehouse receipts for those goods locally present within the State; and this rule applied to whiskey in a foreign country, warehouse receipts for which were held by a person in Kentucky and soiight to be taxed as personal property at owner's domicil.</p> <p>A. tax upon warehouse receipts for goods amounts in substance and effect to a tax upon the goods themselves. Fairbank v. United States, 181 U. S. 283.</p>