The North Carolina Railroad Company v. Story case in 1924 revolved around the issue of taxation on interstate commerce and whether it violated the Commerce Clause of the U.S Constitution. The North Carolina Railroad Company, an interstate carrier, was taxed by Alamance County based on its total system value rather than just its property within county lines. The railroad company argued that this method of taxation unfairly burdened their operations as an entity involved in interstate commerce and thus infringed upon federal jurisdiction over such matters as outlined in the Commerce Clause. However, the Supreme Court ruled against them stating that a state has every right to tax property within its borders for public purposes even if said property is used for both intra-state and inter-state business activities.

In the dissenting opinion for North Carolina Railroad Company v. Story, it was argued that the majority's decision to exempt railroad companies from paying taxes on their property contradicted previous rulings and interpretations of state law. The dissenting justices believed that this exemption unfairly favored corporations over individual taxpayers and disrupted the balance of tax burdens within states. They asserted that railroads should not be considered federal instrumentalities immune from state taxation, as they are private entities engaged in commerce like any other business. Furthermore, they contended that such an interpretation could lead to a dangerous precedent where more businesses seek similar exemptions, thereby undermining states' abilities to collect revenue through taxation.