In the 1896 case of Adams Express Company v. Ohio State Auditor, the U.S. Supreme Court ruled in favor of Ohio's right to tax interstate commerce companies operating within its borders. The Adams Express Company, an interstate carrier company, argued that it was exempt from state taxation due to a clause in the Constitution prohibiting states from taxing interstate commerce without congressional approval. However, the court held that while states cannot impose taxes on goods transported across state lines or services performed outside their jurisdiction (such as transportation), they can levy taxes on property owned by such businesses within their boundaries and income generated therefrom. This decision upheld Ohio's ability to tax corporations like Adams for tangible personal property located in-state and affirmed states' rights over certain aspects of economic regulation.

The dissenting opinion in the case of Adams Express Company v. Ohio State Auditor argued that the majority's decision was inconsistent with previous rulings on similar issues and could lead to unjust taxation practices. The dissenters believed that the tax imposed by Ohio was not a property tax, but rather an excise or privilege tax, which they considered unconstitutional under existing precedents. They contended that if states were allowed to impose such taxes on interstate commerce companies based solely on their gross receipts without considering where those receipts were earned, it would result in unfair double taxation for these businesses as they could be taxed both in their home state and any other state where they operate. This view held that this kind of taxation practice would hinder free trade among states and violate principles of fairness and equity.