The U.S. Supreme Court case Burrill v. Locomobile Company in 1921 involved a dispute over taxation between the Commonwealth of Massachusetts and the Locomobile Company, an automobile manufacturer based in Connecticut but with significant business operations in Massachusetts. The state had levied taxes on the company's inventory stored within its borders, which included completed automobiles as well as parts used for repairs and replacements. The company contested this tax, arguing that it violated their constitutional rights under both the Due Process Clause and Commerce Clause of the Fourteenth Amendment because they were being taxed by two states for essentially same property (Connecticut where they were manufactured and Massachusetts where they were sold). However, the Supreme Court ruled against them stating that there was no violation since each state has authority to tax personal property located within its boundaries even if another state also imposes a similar tax.

In the dissenting opinion for Burrill v. Locomobile Company, Justice McReynolds disagreed with the majority's ruling that Massachusetts' excise tax on foreign corporations was unconstitutional. He argued that there was no violation of due process or equal protection under the Fourteenth Amendment because all corporations, both domestic and foreign, were taxed equally based on their capital stock within Massachusetts. Furthermore, he contended that this case did not involve interstate commerce issues as suggested by the majority; rather it concerned a state’s right to impose taxes on businesses operating within its borders. The justice believed states should have broad powers to levy such taxes without interference from federal courts unless clear constitutional violations are present.