The U.S. Supreme Court case Ashland Oil, Inc. v. Caryl revolved around a dispute between Ashland Oil, a Kentucky-based corporation, and the Tax Commissioner of West Virginia over taxes imposed on the company's activities in West Virginia. The court had to decide whether these taxes violated the Due Process Clause or Commerce Clause of the Constitution because they were levied on income earned outside of West Virginia. Ashland argued that it was unconstitutional for West Virginia to tax its entire net income as this included earnings from interstate commerce occurring outside state borders. However, the Supreme Court disagreed with this argument and upheld West Virginia’s taxation scheme. The court ruled that there was no violation of either clause since Ashland maintained substantial operations within West Virginia and received significant benefits from operating in the state such as police protection and access to courts among others which justified taxing all their profits regardless where they were generated.

In the dissenting opinion for Ashland Oil, Inc. v. Caryl, it was argued that West Virginia's tax on petroleum products did not violate the Commerce Clause of the U.S. Constitution as claimed by Ashland Oil, Inc., a Kentucky-based company with operations in multiple states including West Virginia. The dissenting justices believed that this tax was fairly apportioned and non-discriminatory towards interstate commerce because all businesses selling petroleum products within West Virginia were subject to it regardless of where they were based or whether their business activities crossed state lines. They also pointed out that such taxes are necessary for maintaining infrastructure like roads and bridges which benefit companies like Ashland Oil who use them extensively for transporting goods across state borders.