96 (1906). As to the problem of multiple
taxation of such airplanes, which had in fact been taxed proportionately
by other States, the Court declared that the "taxability of any part of
this fleet by any other State than Minnesota, in view of the taxability
of the entire fleet by that State, is not now before us." Justice
Jackson, in a concurring opinion, would treat Minnesota's right [to tax
as] exclusive of any similar right elsewhere.

[557] Johnson Oil Ref. Co. _v._ Oklahoma ex rel. Mitchell, 290 U.S. 158
(1933).

[558] Pittsburgh, C.C. & St. L.R. Co. _v._ Backus, 154 U.S. 421 (1894).

[559] Wallace _v._ Hines, 253 U.S. 66 (1920).--For example, the ratio of
track mileage within the taxing State to total track mileage cannot be
employed in evaluating that portion of total railway property found in
said State when the cost of the lines in the taxing State was much less
than in other States and the most valuable terminals of the railroad
were located in other States. _See also_ Fargo _v._ Hart, 193 U.S. 490
(1904); Union Tank Line _v._ Wright, 249 U.S. 275 (1919).

[560] Great Northern R. Co. _v._ Minnesota, 278 U.S. 503 (1929).

[561] Illinois Cent. R. Co. _v._ Minnesota, 309 U.S. 157 (1940).

[562] Lawrence _v._ State Tax Commission, 286 U.S. 276 (1932).

[563] Shaffer _v._ Carter, 252 U.S. 37 (1920); Travis _v._ Yale & T.
Mfg. Co., 252 U.S. 60 (1920).

[564] New York ex rel. Cohn _v._ Graves, 300 U.S. 308 (1937).

[565] Maguire _v._ Trefry, 253 U.S. 12 (1920).

[566] Guaranty Trust Co. _v._ Virginia, 305 U.S. 19, 23 (1938).

[567] Whitney _v._ Graves, 299 U.S. 366 (1937).

[568] Underwood Typewriter Co. _v._ Chamberlain, 254 U.S. 113 (1920);
Bass, Ratcliff & Gretton _v._ State Tax Commission, 266 U.S. 271 (1924).

[569] Hans Rees' Sons _v._ North Carolina, 283 U.S. 123 (1931).

[570] Matson Nav. Co. _v._ State Board, 297 U.S. 441 (1936).

[571] Wisconsin _v._ J.C. Penney Co., 311 U.S. 435, 448-449 (1940).
Dissenting, Justice Roberts, along with Chief Justice Hughes and
Justices McReynolds and Reed, stressed the fact that the use and
disbursement by the corporation at its home office of income derived
from operations in many States does not depend on, and cannot be
controlled by, any law of Wisconsin. The act of disbursing such income
as dividends, he contended, is "one wholly beyond the reach of
Wisconsin's sovereign power, one which it cannot effectively command, or
prohibit or condition." The assum