The U.S. Supreme Court case Fidelity Trust and Safety Vault Company v. Louisville in 1898 revolved around a dispute over taxation between the city of Louisville, Kentucky, and the Fidelity Trust and Safety Vault Company. The company argued that it was being unfairly taxed by the city because its capital stock included federal bonds which were not taxable under federal law. The court ruled in favor of the City of Louisville, stating that while federal bonds themselves could not be directly taxed by state or local governments, they could still be considered when determining a corporation's overall value for tax purposes if they are part of its capital stock. Therefore, even though some assets within a corporation’s capital stock may be exempt from direct taxation due to their nature as federally-issued securities (like government bonds), these can still factor into assessments regarding corporate valuation for broader tax considerations.

In the dissenting opinion for Fidelity Trust and Safety Vault Company v. Louisville, the justice argued that the city of Louisville had no right to tax bonds held by a trustee in another state. The dissenting justice believed that this taxation was an infringement on interstate commerce and violated constitutional rights. He contended that such taxes could potentially lead to double taxation if other states followed suit, which would be detrimental to economic growth and stability. Furthermore, he asserted that it was unjust for a state to impose taxes on property located outside its jurisdiction as it does not have any authority or control over such assets. This view opposed the majority's decision which upheld Louisville's right to levy these taxes based on domicile of ownership rather than location of property.