US SUPREME COURT DECISIONS

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 noncitizens 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 manufacture without and sell within the state. Held that the license tax, as applied to a New Jersey corporation and as computed on the basis of merchandise manufactured by it in 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 chanrobles.com-red

Page 246 U. S. 2

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.

118 Va. 242 affirmed.

The case is stated in the opinion. chanrobles.com-red

Page 246 U. S. 3