In Railroad Company v. Collector, the Supreme Court of the United States was asked to decide whether a tax imposed by the state of Illinois on the gross receipts of a railroad company was constitutional. The railroad company argued that the tax was unconstitutional because it violated the Due Process Clause of the Fourteenth Amendment. The Supreme Court held that the tax was constitutional because it was a valid exercise of the state's power to tax. The Court reasoned that the tax was not arbitrary or oppressive, and that it was applied uniformly to all railroads operating in the state. Furthermore, the Court noted that the tax was not so high as to be confiscatory. The Court concluded that the tax was a valid exercise of the state's power to tax and did not violate the Due Process Clause of the Fourteenth Amendment.

In Railroad Company v. Collector, the Supreme Court was tasked with determining whether a tax imposed by Congress on railroad companies was constitutional. The majority opinion held that it was not, as the tax violated the Fifth Amendment's prohibition against taking private property for public use without just compensation. Justice Field dissented from this ruling and argued that Congress had acted within its authority in imposing such a tax, citing previous cases which established that taxes are an appropriate exercise of congressional power when they are used to raise revenue for public purposes. He further noted that while there may be some burden placed on railroads due to the imposition of this particular tax, it is no different than any other kind of taxation and does not constitute a taking under the Fifth Amendment since it does not deprive them of their property or interfere with their rights in any way.