the same category of
unconstitutional taxation of the interstate commerce privilege, the
Court has also included the following: a State "franchise" tax on a
foreign corporation, whose sole business in the State consisted in
landing, storing and selling in the original package goods imported by
it from abroad, the tax being imposed annually on the doing of such
business and measured by the value of the goods on hand;[633] a State
privilege or occupation tax on every corporation engaged in the business
of operating and maintaining telephone lines and furnishing telephone
service in the State, of so much for each telephonic instrument
controlled and operated by it, as applied to a company furnishing both
interstate and intrastate service, and employing the same telephones,
wires, etc., in both as integrated parts of its system;[634] a State
occupation tax measured by the entire gross receipts of the business of
a radio broadcasting station, licensed by the Federal Communications
Commission, and engaged in broadcasting advertising "programs" for
customers for hire to listeners within and beyond the State, since it
did not "appear that any of the taxed income ... [was] allocable to
interstate commerce";[635] a State occupation tax on the business of
loading and unloading vessels engaged in interstate and foreign
commerce;[636] an Indiana income tax imposed on the gross receipts from
commerce inasmuch as the tax reached indiscriminately and without
apportionment the gross income from both interstate commerce and
intrastate activities;[637] an Arkansas statute making entry into the
State of motor vehicles carrying more than twenty gallons of gasoline
conditional on the payment of an excise on the excess.[638]

DOCTRINE OF WESTERN UNION TELEGRAPH _v._ KANSAS EX REL. COLEMAN

One of the most striking concessions ever made by the Court to the
interstate commercial interest at the expense of the State's taxing
power was that which appeared originally in 1910, in Western Union
Telegraph. Co. _v._ Kansas ex rel. Coleman,[639] which involved a
percentage tax upon the total capitalization of all foreign corporations
doing or seeking to do a local business in the State. The Court
pronounced the tax, as to the Western Union, a burden upon the company's
interstate business and upon its property located and used outside the
State, and hence void under both the commerce clause and the due process
of law clause of the Fourteenth Amendme