In the 1917 case of International & Great Northern Railway Company v. Anderson County, the U.S. Supreme Court addressed a dispute over taxation between a railway company and several Texas counties. The railway company argued that it was being unfairly taxed by these counties because they were not taking into account the value depreciation of its properties due to wear and tear, obsolescence, or other forms of deterioration when assessing property taxes. The court ruled in favor of the counties stating that while physical deterioration could be considered for tax purposes under Texas law, economic factors such as decreased profitability could not be used to lower assessed values for tax purposes. Therefore, even though some parts of their rail lines may have been less profitable than others due to various reasons like competition or changes in industry conditions - this did not constitute grounds for reducing their taxable value.

In the dissenting opinion for International & Great Northern Railway Company v. Anderson County, Justice Holmes disagreed with the majority's ruling that a Texas law requiring railroads to maintain fences along their tracks was constitutional. He argued that this requirement constituted an unreasonable burden on interstate commerce and therefore violated the Commerce Clause of the U.S Constitution. According to him, it was not within a state's power to impose such regulations on railroad companies operating across state lines as they were engaged in interstate commerce which fell under federal jurisdiction. Furthermore, he contended that if every state imposed its own unique set of requirements on these companies, it would create an untenable situation where railroads would be subject to conflicting laws from different states thereby hampering smooth operations and efficiency.