In the 1983 case of Aloha Airlines, Inc. v. Director of Taxation of Hawaii, the U.S. Supreme Court ruled in favor of Aloha Airlines regarding a dispute over state taxation on gross income derived from interstate commerce activities. The court held that under the Commerce Clause and Fourteenth Amendment's Due Process Clause, states cannot tax airlines for revenue generated outside their jurisdictional boundaries even if they have substantial nexus with those states due to regular flights or other operations there. This decision was based on an interpretation that such taxes would unfairly burden interstate commerce and violate constitutional principles by allowing multiple jurisdictions to impose taxes on the same income source without apportionment according to where it was earned.

In the dissenting opinion for Aloha Airlines, Inc. v. Director of Taxation of Hawaii, it was argued that the majority's decision to uphold a state tax on gross income from interstate transportation contradicted previous Supreme Court rulings which held such taxes as unconstitutional burdens on interstate commerce. The dissent pointed out that this ruling effectively allowed states to impose their own regulatory schemes onto interstate businesses and potentially disrupt uniform national regulation in areas like aviation where federal control is paramount. Furthermore, they contended that the court failed to properly apply its own four-part test established in Complete Auto Transit v Brady (1977) for determining whether a state tax violates the Commerce Clause - particularly regarding fair apportionment and discrimination against interstate commerce.