The U.S. Supreme Court case McGoldrick v. Berwind-White Coal Mining Co., in 1939, revolved around the issue of whether a city could impose taxes on goods that were sold for immediate export. The Berwind-White Coal Mining Company argued that New York City's tax on its coal sales violated the Import-Export Clause of the Constitution because it was an indirect tax on exports and thus unconstitutional. However, Comptroller McGoldrick contended that since the tax was imposed before title transfer and delivery to foreign buyers occurred, it did not infringe upon federal authority over international commerce or violate any constitutional provisions. In a decision favoring McGoldrick, Justice Benjamin Cardozo wrote for majority stating that as long as taxation occurs within state borders and prior to final act of exportation (i.e., shipment), such taxes are permissible under constitution; they do not interfere with federal government’s exclusive power over foreign trade nor constitute prohibited duties on exports.

In the dissenting opinion for McGoldrick v. Berwind-White Coal Mining Co., Justice McReynolds disagreed with the majority's view that New York City had the right to tax goods in transit, arguing it violated interstate commerce laws. He believed that this decision would lead to a chaotic situation where every municipality could impose taxes on goods passing through their jurisdiction, leading to an untenable burden on interstate commerce. Furthermore, he argued that such taxation was not within the purview of states or cities but rather fell under federal jurisdiction as per constitutional provisions regarding interstate trade regulation. This ruling, according to him, undermined these principles and threatened free trade among states by allowing local jurisdictions undue power over national economic activity.