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 unconstitutional. The railroad company argued that the tax was a direct tax on the property of the company, and thus was prohibited by the Constitution. The Collector argued that the tax was an excise tax, and thus was not prohibited by the Constitution. The Court held that the tax was an excise tax, and thus was not prohibited by the Constitution. The Court reasoned that the tax was imposed on the privilege of doing business, and not on the property of the company. The Court noted that the tax was imposed on the gross receipts of the company, and not on the value of the property of the company. The Court also noted that the tax was imposed on the privilege of doing business, and not on the property of the company. The Court concluded that the tax was an excise tax, and thus was not prohibited by the Constitution. The Court held that the tax was valid, and that the Collector was entitled to collect the tax from the railroad company.

In Railroad Company v. Collector, the Supreme Court was asked to decide whether a tax imposed by Congress on railroad companies was constitutional. The majority opinion held that it was not, as the tax violated the Due Process Clause of the Fifth Amendment and constituted an unconstitutional taking of property without just compensation. Justice Field dissented from this decision, arguing that Congress had acted within its authority in enacting this law and imposing taxes upon railroads for their use of public lands granted to them by federal legislation. He argued further that due process did not require payment for such uses since they were authorized under existing laws and regulations; thus, no deprivation or taking occurred when these taxes were imposed upon railroads using public lands in accordance with those laws and regulations.