The U.S. Supreme Court case Central Greyhound Lines, Inc. v. Mealey et al., 1947 revolved around a tax dispute between the state of New York and Central Greyhound Lines, a bus company that operated interstate routes across several states including New York. The State had imposed an apportioned gross receipts tax on the company's total revenue from ticket sales for trips that began or ended in New York but also crossed into neighboring states (interstate commerce). The bus company argued this taxation was unconstitutional as it violated the Commerce Clause by burdening interstate commerce. The Supreme Court ruled in favor of Central Greyhound Lines, finding that while states could impose taxes on businesses operating within their borders, they couldn't levy taxes on portions of interstate business activity occurring outside their jurisdictional boundaries. Therefore, taxing all revenues from these multi-state journeys unfairly taxed activities taking place beyond its borders and thus constituted an undue burden on interstate commerce.

The dissenting opinion in the Central Greyhound Lines, Inc. v. Mealey case argued that New York State's taxation of gross receipts from interstate bus operations was not a violation of the Commerce Clause as it did not create an undue burden on interstate commerce. The dissenters believed that this tax was fairly apportioned and non-discriminatory, therefore it should be upheld under the Court’s Complete Auto Transit test for state taxes affecting interstate commerce. They pointed out that other states also taxed these revenues without causing any disruption to business operations or creating unfair competition between companies operating solely within one state versus those with multi-state operations. Furthermore, they contended that if every state imposed similar taxes on such businesses proportionately based on their intrastate activities, there would be no risk of multiple taxation which is what the Commerce Clause seeks to prevent.