In the case of The Pullman Company v. Croom, Comptroller of the State of Florida in 1913, the U.S Supreme Court ruled on a dispute concerning taxation. The Pullman Company, an Illinois corporation that manufactured and leased railroad cars across multiple states including Florida, challenged a tax imposed by Florida's comptroller. The company argued that it was being unfairly taxed twice: once for its tangible property (the railroad cars) located within state lines and again for intangible property (its capital stock). However, the court upheld Florida’s right to levy both taxes. It determined that while there may be some overlap between tangible and intangible assets in this context, they were not identical entities; therefore each could be separately taxed under state law without violating constitutional protections against double jeopardy or deprivation of property without due process.

In the dissenting opinion for The Pullman Company v. Croom, Comptroller of the State of Florida case in 1913, Justice Holmes disagreed with the majority's decision that a tax imposed by Florida on The Pullman Company was unconstitutional. He argued that there is no constitutional principle preventing a state from taxing an out-of-state corporation operating within its borders if it provides services to residents and uses local resources. According to him, such taxes are not discriminatory or unreasonable as they reflect compensation for benefits provided by the state like police protection and public infrastructure use. Furthermore, he contended that interstate commerce should not be immune from taxation but rather subject to fair apportionment based on activities conducted within each state’s jurisdiction.