The case of Arizona Department of Revenue v. Blaze Construction Company, Inc., 1998 revolved around the issue of tax imposition on a non-resident corporation operating in Arizona. Blaze Construction, a Montana-based company, was contracted for various construction projects in Arizona but did not have an office or employees permanently stationed there. The State's Department of Revenue sought to impose transaction privilege and use taxes on the firm’s gross income from these contracts. However, Blaze argued that this violated the Due Process Clause and Commerce Clause of the U.S Constitution as it had no substantial nexus with Arizona. The Supreme Court ruled in favor of the state department stating that physical presence is not necessary to establish substantial nexus under Complete Auto Transit test (a four-pronged analysis used by courts to determine if a state tax violates commerce clause). It held that out-of-state corporations can be subjected to taxation if they are benefiting from services provided by the taxing state such as police protection or infrastructure usage which was true for Blaze Construction during its operations within Arizona.

The dissenting opinion in the case of Arizona Department of Revenue v. Blaze Construction Company, Inc., argued that the majority's decision was inconsistent with previous rulings and interpretations of federal law. The dissent believed that the tax imposed by Arizona on out-of-state companies like Blaze Construction was not discriminatory because it applied equally to all businesses operating within its borders, regardless of where they were based. They also disagreed with the majority's view that this tax violated interstate commerce principles, arguing instead that it simply required companies to pay for services provided by the state such as road maintenance - a cost directly related to their business operations. Furthermore, they pointed out inconsistencies between this ruling and earlier decisions which upheld similar taxes in other states.