United States Express Co. v. Minnesota

Citations

• 223 U.S. 335
• 32 S. Ct. 211
• 56 L. Ed. 459
• 1912 U.S. LEXIS 2238

Syllabus

<p>In determining whether a state tax on earnings is constitutional this court is bound by the decision of thp state court as to what classes of earnings are included1 in estimating the earnings to' be taxed.</p> <p>A State may tax property within.the State although it is used in interstate commerce. '</p> <p>A State may not burden interstate commerce by taxing its commerce, but it may measure the value of property of a corporation, engaged in interstate commerce within the State by the gross receipts, and . impose a tax thereon if the same is in lieu of all taxes upon the property of such corporation.’ Oklahoma v. Wells, Fargo '& Co., ante, p. 298, distinguished.'</p> <p>It is difficult, at times, to draw the line between state taxes that aré unconstitutional as burdening interstate commerce.and a legitimate • property tax measured in.part by income from interstate commerce. While the determination by the. state court that a tax so measured is a property tax is not binding on. this court, in this case, this court wilTnot say that the conclusion is not well founded.</p> <p>The Minnesota'statutes, Revised Laws, 1905, Chapter 11, taxing express companies on their property employed within the State six per cent of the gross receipts in’ lieu of all other taxes, is an exercise in good faith of legitimate taxing power, and is not an unconstitutional burden upon interstate commerce.</p>