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In the case of General Motors Corp. v. District of Columbia (1964), the U.S Supreme Court ruled in favor of General Motors Corporation (GM). The dispute arose when GM challenged a tax assessment by the District of Columbia, arguing that it was unconstitutional and violated their right to due process under law as per the Fifth Amendment. The court agreed with GM's argument that its property was being taxed twice: once where it was physically located and again in D.C., even though they had no physical presence or operations there. This decision established an important precedent regarding interstate commerce, taxation, and jurisdictional issues for corporations operating across state lines.
In the dissenting opinion for General Motors Corp. v. District of Columbia, it was argued that the majority's decision to allow a tax on inventory held outside of D.C., but owned by a corporation operating within its jurisdiction, set an alarming precedent. The dissenting justices expressed concern over potential double taxation issues and believed this ruling could lead to unfair treatment of corporations who maintain inventories in multiple jurisdictions. They contended that such taxes should be levied based on where property is physically located rather than where ownership resides, as per traditional principles of interstate commerce taxation. Furthermore, they disagreed with the majority's interpretation of "business situs," arguing it shouldn't apply when goods are stored temporarily in another state before being sold in D.C., as was the case with GM’s cars.