In the case of International Harvester Credit Corp. et al. v. Goodrich et al., constituting the State Tax Commission of New York, 1955, the Supreme Court ruled in favor of International Harvester Credit Corporation (IHCC). The issue at hand was whether IHCC's business operations were subject to franchise tax under New York law as a corporation doing business within state borders or if it was exempt due to its primary function being interstate commerce. The court held that while IHCC did have offices and employees in New York, their main purpose was to facilitate out-of-state transactions for equipment manufactured by International Harvester Company outside of New York state and sold through independent dealers across various states including New York. Therefore, these activities constituted interstate commerce which is protected from state taxation under U.S Constitution’s Commerce Clause.

The dissenting opinion in the case of International Harvester Credit Corp. et al. v. Goodrich et al., argued that the majority's decision to uphold New York's tax on out-of-state corporations was unfair and unconstitutional, as it violated the Commerce Clause of the U.S Constitution which prohibits states from passing legislation that discriminally affects interstate commerce. The dissenters believed that this tax placed an undue burden on out-of-state companies, effectively discriminating against them in favor of local businesses and thus interfering with free trade among states. They contended that such a state-imposed barrier to interstate commerce should not be allowed under federal law, regardless of whether or not it served a legitimate state interest or purpose.