The U.S. Supreme Court case Hallanan, State Tax Commissioner, et al. v. Eureka Pipe Line Company in 1922 revolved around the issue of taxation on interstate commerce and property valuation for tax purposes. The Eureka Pipe Line Company operated a pipeline that ran through several states including West Virginia where it was taxed by the state's tax commissioner, Mr. Hallanan. The company argued that this taxation was unconstitutional as it violated the Commerce Clause of the Constitution which prohibits states from taxing interstate commerce activities without congressional approval. The court ruled in favor of Eureka stating that their operations constituted interstate commerce and thus were not subject to state taxes under current law at that time - a decision based on an interpretation of what constitutes "interstate" activity versus "intrastate". This ruling set important precedent regarding how companies operating across multiple states could be taxed.

In the dissenting opinion for Hallanan, State Tax Commissioner, et al. v. Eureka Pipe Line Company case in 1922, Justice Holmes disagreed with the majority's ruling that West Virginia's tax on oil transported through pipelines was unconstitutional under the Commerce Clause of the U.S. Constitution. He argued that a state should have authority to impose taxes on businesses operating within its borders as long as it does not discriminate against interstate commerce or place an undue burden upon it - which he did not believe this tax did. He also pointed out that other forms of transportation such as railroads and boats were subject to similar taxation without violating the Commerce Clause because they used local resources and infrastructure provided by states where they operated; therefore, pipelines should be treated no differently.