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In the 1957 case of American Motors Corp. et al. v. City of Kenosha, the U.S Supreme Court ruled in favor of American Motors Corporation (AMC). The dispute arose when AMC was assessed for property taxes by the city of Kenosha, Wisconsin on its inventory that was stored in transit at a public warehouse within city limits but destined for out-of-state locations. AMC argued that this taxation violated their rights under both the Commerce Clause and Due Process Clause as it interfered with interstate commerce and lacked jurisdictional basis respectively. The court agreed with AMC's argument stating that goods which are merely passing through or temporarily located within a state cannot be subjected to local taxation because they are part of interstate commerce.
In the dissenting opinion for American Motors Corp. et al. v. City of Kenosha, it was argued that the majority's decision to uphold a Wisconsin law imposing property taxes on machinery and equipment used in manufacturing was incorrect because it violated the Due Process Clause of the Fourteenth Amendment. The dissent contended that this tax burdened interstate commerce disproportionately, as it only applied to manufacturers who produced goods for sale outside Wisconsin while exempting those who sold within state lines. This selective taxation created an unfair advantage for local businesses over out-of-state competitors, which contradicted principles of fair competition and equal protection under federal law. Furthermore, they believed that such discriminatory treatment could potentially lead to economic retaliation from other states against Wisconsin-based companies - a situation contrary to national unity and free trade among states.