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In the case of Meyer, Auditor of the State of Oklahoma v. Wells Fargo & Company (1911), the Supreme Court ruled in favor of Wells Fargo. The dispute arose when Oklahoma attempted to tax Wells Fargo for conducting business within its borders without a physical presence or property in the state. The court held that states could not impose taxes on businesses solely because they conducted interstate commerce within their boundaries, as this would violate federal jurisdiction over such matters under the Commerce Clause of Constitution. This decision reinforced and clarified earlier rulings which established that only Congress has authority to regulate interstate commerce, thereby preventing individual states from imposing burdensome taxes or regulations on out-of-state companies.
In the dissenting opinion for Meyer v. Wells, Fargo & Company, it was argued that the majority's decision to strike down Oklahoma's tax statute as unconstitutional was incorrect. The dissenting justices believed that states have a right to impose taxes on corporations operating within their borders and disagreed with the majority’s interpretation of due process rights in this context. They contended that there is no constitutional prohibition against double taxation and therefore Oklahoma should be allowed to levy taxes on both Wells Fargo’s gross receipts and its property located within state lines. Furthermore, they maintained that such taxation does not violate interstate commerce regulations because it applies equally to all businesses regardless of whether they operate across state lines or solely within Oklahoma.