In the case of Minnesota v. National Tea Co., 1939, the U.S Supreme Court was tasked with determining whether a state could impose taxes on an out-of-state corporation for goods stored in public warehouses within its jurisdiction before being shipped to retailers. The National Tea Company, incorporated in Delaware and Illinois but operating stores in Minnesota, argued that such taxation violated the Due Process Clause of the Fourteenth Amendment as well as interstate commerce laws. However, the court ruled against them stating that since they had availed themselves of "the protection and benefit" provided by Minnesota's government while their goods were stored there awaiting distribution to local retail outlets; it was only fair for them to pay tax contributions towards maintaining those benefits and protections. Therefore, this ruling affirmed states' rights to levy taxes on corporations operating within their borders even if they are incorporated elsewhere.

In the dissenting opinion for Minnesota v. National Tea Co., Justice McReynolds disagreed with the majority's decision to uphold a tax on chain stores in Minnesota. He argued that this law was discriminatory and violated the Equal Protection Clause of the Fourteenth Amendment, as it unfairly targeted businesses based on their structure rather than their income or property value. Furthermore, he contended that there was no rational basis for such discrimination because all businesses contribute to public expenses through taxes and should therefore be treated equally by tax laws. In his view, allowing states to impose additional taxes on certain types of businesses could lead to arbitrary and oppressive taxation practices.