The U.S. Supreme Court case J.D. Adams Manufacturing Co. v Storen, Chief Administrative Officer et al., 1937 revolved around the constitutionality of an Indiana gross income tax law that taxed interstate commerce and was therefore claimed to be in violation of the Commerce Clause of the Federal Constitution. The plaintiff, J.D Adams Manufacturing Company, argued that this taxation on its sales across state lines infringed upon federal jurisdiction over interstate commerce as per Article I Section 8 Clause 3 (the Commerce Clause) of the US Constitution. However, the court ruled against them stating that a tax levied by a state for revenue purposes which only incidentally affects interstate commerce does not violate this clause unless it discriminates against or places an undue burden on such trade.

In the dissenting opinion for J.D. Adams Manufacturing Co. v Storen, Chief Administrative Officer et al., Justice Benjamin Cardozo disagreed with the majority's decision that Indiana's gross income tax was unconstitutional because it violated interstate commerce laws and due process rights. He argued that a state has every right to impose taxes on businesses operating within its borders, even if those businesses also operate in other states or countries. Furthermore, he contended that this taxation does not violate due process rights as long as it is applied fairly and uniformly across all similar entities in the state. The justice believed that striking down such a law could potentially undermine states' abilities to generate revenue through taxation of corporations doing business within their jurisdictions.