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In the case of Oklahoma Natural Gas Company v. State of Oklahoma et al., 1921, the Supreme Court was asked to determine whether a state could impose a tax on natural gas companies for gas produced within its borders but sold and delivered in another state. The plaintiff, Oklahoma Natural Gas Company (ONGC), argued that such taxation violated both the Due Process Clause and Commerce Clause of the U.S Constitution as it amounted to double taxation since they were already paying taxes in states where their consumers resided. However, after careful consideration, the court ruled against ONGC's claims stating that there was no constitutional impediment preventing a state from taxing products manufactured or grown within its boundaries before being shipped out-of-state for sale. The court held that this did not constitute double taxation because each tax is levied by different entities - one by the producing state and another by consuming states based on sales transactions.
In the dissenting opinion for Oklahoma Natural Gas Company v. State of Oklahoma et al., Justice McReynolds disagreed with the majority's decision to uphold a state law that required pipeline companies to obtain approval from a state commission before selling natural gas outside of the state. He argued that this requirement violated both interstate commerce and due process clauses in the U.S Constitution, as it gave undue power to one entity (the commission) over private business decisions. Furthermore, he contended that such regulation could lead to arbitrary or discriminatory practices by allowing states too much control over resources within their borders at potential detriment to other states' interests. Therefore, he believed this case should have been decided in favor of free trade across state lines without interference from individual states.