In the case of Raymond, County Treasurer v. Chicago Edison Company in 1907, the U.S. Supreme Court ruled on a dispute over taxation between Cook County, Illinois and the Chicago Edison Company. The county had imposed taxes on poles, wires and other equipment used by the company to distribute electricity throughout its service area. The company argued that this property was exempt from local taxation under an Illinois state law which stated that capital invested in personal property located outside of Illinois but employed in conducting business within it should not be taxed locally if it is already being taxed elsewhere. The court sided with Cook County stating that while some elements of interstate commerce were involved due to power lines crossing state borders; however, most of these properties were permanently located within Illinois and thus subject to local tax laws regardless if they are also part of an interstate network or system. Therefore, even though certain parts may cross into another jurisdiction for purposes related to their function as components in a larger system does not make them immune from local taxes where they are physically situated.

In the dissenting opinion for Raymond, County Treasurer v. Chicago Edison Company, Justice Harlan disagreed with the majority's interpretation of tax law and its application to this case. He argued that a state has an inherent power to tax all property within its jurisdiction unless expressly prohibited by constitutional provisions. The majority's ruling effectively exempted certain properties from taxation based on their use rather than their location or ownership, which he believed was not in line with established principles of taxation. Furthermore, he contended that such exemptions should be explicitly stated in legislation if intended by lawmakers and not inferred through judicial interpretation as done by the majority. In his view, every presumption should be against any implied exemption from taxation because it is a burden shared collectively for public purposes.