cular cases." The
decisions in the Underwood and Bass cases, _supra_, "are not authority
for the conclusion that where a corporation manufactures in one State
and sells in another, the net profits of the entire transaction, as a
unitary enterprise, may be attributed, regardless of evidence, to either
State."

[720] Atlantic Coast Line _v._ Daughton, 262 U.S. 413 (1923).

[721] Matson Nav. Co. _v._ State Board, 297 U.S. 441 (1936). _See also_
Butler Bros. _v._ McColgan, 315 U.S. 501 (1942), where the tax was
sustained under the Fourteenth Amendment.

[722] Memphis Gas Co. _v._ Beeler, 315 U.S. 649 (1942).

[723] Ibid. 656-657

[724] Spector Motor Service _v._ O'Connor, 340 U.S. 602 (1951).

[725] 114 U.S. 196 (1885).

[726] Hays _v._ Pacific Mail S.S. Co., 17 How. 596 (1855).

[727] Packet Co. _v._ Keokuk, 95 U.S. 80 (1877); _see also_
Transportation Co. _v._ Parkersburg, 107 U.S. 691 (1883).

[728] Ayer & L. Tie Co. _v._ Kentucky, 202 U.S. 409 (1906). For a resume
of the rules for taxing vessels _see_ Northwest Airlines _v._ Minnesota,
322 U.S. 292, 314-315 (1944), note 2.

[729] Old Dominion S.S. Co. _v._ Virginia, 198 U.S. 299 (1905): a vessel
enrolled in New York at domicile of owner, but operating wholly in
Virginia, was held taxable in Virginia.

[730] 336 U.S. 169 (1949).

[731] Northwest Airlines _v._ Minnesota, 322 U.S. 292 (1944).

[732] He also invoked New York Central and H.R.R. Co. _v._ Miller, 202
U.S. 584 (1906), where although 12 to 64 per cent of the rolling stock
of the railroad was outside of New York throughout the tax year, New
York was nevertheless allowed to tax it all because no part was in any
other State throughout the year. The case is atypical, a constitutional
sport; _cf._ Union Refrigerator Transit Co. _v._ Kentucky, 199 U.S. 194
(1905).

[733] 322 U.S. at 301-302.

[734] "The apportionment theory is a mongrel one, a cross between desire
not to interfere with State taxation and desire at the same time not
utterly to crush out interstate commerce. It is a practical, but rather
illogical, device to prevent duplication of tax burdens on vehicles in
transit. It is established in our decisions and has been found more or
less workable with more or less arbitrary formulae of apportionment.
Nothing either in theory or in practice commends it for transfer to air
commerce."--Ibid. 306.

[735] Ibid. 308.

[736] Pullman's Palace Car Co. _v._ Pennsylvania, 141 U.S. 18 (1891).

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