In the case of Choctaw, Oklahoma & Gulf Railroad Company v. Tennessee in 1903, the U.S Supreme Court ruled on a dispute involving taxation and interstate commerce. The state of Tennessee had imposed taxes on the Choctaw, Oklahoma & Gulf Railroad Company for its operations within the state. However, this railroad company was incorporated in another state and argued that it should not be subject to these taxes as they interfered with interstate commerce. The court disagreed with this argument and upheld Tennessee's right to tax businesses operating within its borders regardless of where they were incorporated or headquartered. This decision affirmed states' rights to regulate business activities occurring within their jurisdictions even if those businesses are involved in interstate trade.

In the dissenting opinion for the case of Choctaw, Oklahoma & Gulf Railroad Company v. Tennessee, it was argued that a state should not have the power to tax property located outside its jurisdiction. The justice contended that while states can levy taxes on corporations operating within their borders, they should not be able to extend this taxing power beyond their territorial limits. This argument was based on principles of fairness and respect for other jurisdictions' sovereignty rights. Furthermore, he believed that allowing such taxation could lead to double taxation if another state also decided to tax the same property - an outcome which would be unjust and burdensome for businesses. Thus, in his view, only federal authorities should have the right to impose taxes on interstate commerce or properties situated across different states.