The case of People of the State of New York on the Relation of Cornell Steamboat Company v. Sohmer, 1914, revolved around a taxation dispute. The Cornell Steamboat Company challenged an assessment by the state comptroller for taxes on its capital stock. The company argued that it was unconstitutional as it included property located and business transacted outside New York state in violation of due process under Fourteenth Amendment rights. However, the Supreme Court ruled against them stating that while states cannot tax out-of-state properties or operations directly, they can consider these factors when determining a corporation's overall value for in-state taxation purposes. Therefore, including out-of-state assets to calculate tax did not violate constitutional protections.

The dissenting opinion in the case of People of the State of New York on the Relation of Cornell Steamboat Company v. Sohmer, as Comptroller of the State Of New York, argued that there was no violation to equal protection under law by imposing a tax on corporations based on their capital stock value. The justice disagreed with majority's view that this taxation method unfairly targeted out-of-state companies and violated interstate commerce regulations. He believed it was within states' rights to levy such taxes for revenue purposes and did not see it as an attempt to regulate or burden interstate commerce. Furthermore, he pointed out that all corporations operating within state boundaries were subject to same tax rules regardless if they conducted business across state lines or not; thus maintaining equality among businesses.