U.S. Supreme Court
Oliver Iron Mining Co. v. Lord, 262 U.S. 172 (1923)
Oliver Iron Mining Co. v. Lord
Argued December 6, 7, 1922
Decided May 7, 1923
262 U.S. 172
1. The tax imposed by Laws of Minnesota, 1921, c. 223, on the business of mining iron ore, measured by a percentage of the value of the ore mined or produced, is an occupation tax. P. 262 U. S. 176.
2. The mining of ore, even when substantially all of the ore mined is immediately and continuously loaded on cars and shipped into other states to satisfy existing contracts, is not interstate commerce, and is subject to local taxation. P. 262 U. S. 177.
3. The facts that the Minnesota tax, supra, applies only to those engaged, as owners or lessees, in mining or producing ores on their own account, and not to those who do mining work for them chanroblesvirtualawlibrary
under contract and whose pay is part of the expenses of the business, and that it does not apply to owners or lessees who do development work, but remove no ore, do not bring it in conflict with the equal protection clause of the Fourteenth Amendment, or with § 1 of Art. 9 of the Minnesota Constitution, providing that taxes shall be uniform upon the same class of subjects. P. 179.
4. The question whether a provision of this Minnesota law allowing the amount of royalties paid on the ore mined and produced during the year to be deducted from the value of such ore before computing the tax introduces an unconstitutional discrimination in favor of those who operate under leases and pay royalties and against owners who operate their own mines and pay no royalties cannot be raised in this case, it appearing that all of the iron mines in the state are operated under such leases except six which were not operated during the tax year in question and are not threatened with a tax for that or later years. P. 262 U. S. 180.
5. A tax based on the value of ore mined and produced, after deducting royalties and major expenses of the business, cannot be adjudged arbitrary or unreasonably discriminatory merely because of lack of uniformity in royalties and expenses producing corresponding differences in the tax. P. 262 U. S. 181.
Appeals from decrees of the district court dismissing, on their merits, as many suits, brought by the appellants to enjoin the enforcement of a state tax law. chanroblesvirtualawlibrary