The U.S. Supreme Court case General American Tank Car Corporation et al. v. Day, Sheriff and Ex-Officio Tax Collector in 1925 revolved around a dispute over taxation of property located outside the state of Louisiana but owned by corporations operating within the state. The plaintiffs, including General American Tank Car Corporation, argued that this form of taxation was unconstitutional as it violated their due process rights under the Fourteenth Amendment since they were being taxed for property not within Louisiana's jurisdiction. However, the Supreme Court ruled against them stating that while states cannot tax personal property situated beyond its borders directly, they can tax an equivalent amount based on all properties owned by a corporation operating within its territory regardless of where those properties are physically located. This decision upheld Louisiana’s right to impose such taxes and reinforced states' authority to levy taxes on corporations doing business within their boundaries.

In the dissenting opinion for General American Tank Car Corporation et al. v. Day, Sheriff and Ex-Officio Tax Collector, Justice McReynolds argued that Louisiana's taxation of movable property located temporarily within its borders was not unconstitutional. He contended that the state had a right to tax such properties as they were physically present in Louisiana and enjoyed protection under its laws during their stay. The majority ruling held this form of taxation as an undue burden on interstate commerce; however, Justice McReynolds disagreed with this interpretation of the Commerce Clause. He believed it was unreasonable to exempt transient commodities from local taxes while other properties within the state were subject to them.