The U.S. Supreme Court case McNutt, Governor of Indiana, et al. v. General Motors Acceptance Corp., 1935 revolved around the issue of taxation and valuation methods used by the state of Indiana on out-of-state corporations operating within its borders. The plaintiff was General Motors Acceptance Corporation (GMAC), which challenged an increased tax assessment made by Indiana's Tax Board arguing that it was arbitrary and violated due process rights under the Fourteenth Amendment because it exceeded GMAC’s total capital and surplus in all states combined. The Supreme Court ruled in favor of GMAC stating that while states have broad powers to levy taxes for revenue purposes, they must do so based on some rational method or formula rather than arbitrarily assigning values for tax purposes without any factual basis or explanation. The court held that if a taxpayer challenges such an assessment as being excessive, then it is up to the taxing authority - not the taxpayer - to provide evidence justifying their valuation.

In the dissenting opinion for McNutt, Governor of Indiana, et al. v. General Motors Acceptance Corp., Justice Stone argued that the majority's decision to remand the case back to state court was incorrect because it failed to consider whether or not there was a substantial federal question involved in this dispute over taxation. He believed that if such a question existed, then it should be decided by federal courts rather than state courts due to their expertise and jurisdiction over constitutional matters. Furthermore, he disagreed with the majority's view that General Motors had not adequately shown its claim exceeded $3,000 (the amount required at that time for federal jurisdiction), arguing instead they had provided sufficient evidence of excessive taxation by Indiana officials which could potentially result in damages exceeding this threshold amount.