In the case of Crescent Cotton Oil Company v. State of Mississippi, 1921, the Supreme Court ruled on a dispute regarding taxation. The Crescent Cotton Oil Company was incorporated in Louisiana but had property and conducted business in Mississippi as well. The state of Mississippi sought to tax all shares owned by residents and non-residents alike for their total value without deducting debts owed by the company elsewhere. This led to double taxation since Louisiana also taxed these shares based on their full value without considering debts owed outside its jurisdiction. The oil company argued that this violated both due process and equal protection clauses under the Fourteenth Amendment because it resulted in an unfair burden being placed upon them compared to other corporations operating solely within one state's boundaries. However, the Supreme Court upheld Mississippi's right to impose such taxes stating that there is no constitutional requirement for states to adjust their methods of valuation or apportionment so as not to overlap with those used by another state where a corporation may also be liable for taxes.

In the dissenting opinion for Crescent Cotton Oil Company v. State of Mississippi, it was argued that the state's tax on cotton seed crushed within its borders violated both the Due Process and Commerce Clauses of the Constitution. The justice contended that this tax unfairly burdened interstate commerce as it applied only to seeds crushed in-state, thereby discriminating against out-of-state businesses who bought seeds from Mississippi but processed them elsewhere. Furthermore, he believed that taxing a business operation based solely on where an initial step took place (i.e., crushing) rather than considering all steps involved in producing final products was arbitrary and capricious, thus violating due process rights. He also pointed out inconsistencies with previous court rulings regarding similar taxation issues which further underscored his disagreement with majority decision.