In the Saranac Land and Timber Company v. Comptroller of New York case in 1899, the Supreme Court ruled on a dispute over taxation between a corporation and the state. The Saranac Land and Timber Company, incorporated in Michigan but owning property in New York, contested that it was being unfairly taxed by New York State for its holdings there. The company argued that since they were not physically present or conducting business within the state beyond mere ownership of land, they should not be subjected to such taxes. However, the court disagreed with this argument stating that states have jurisdiction to tax personal property located within their borders regardless of where an entity is incorporated or conducts most of its business activities. Therefore, it upheld New York's right to levy taxes against out-of-state corporations for properties held within its boundaries.

In the dissenting opinion for Saranac Land and Timber Company v. Comptroller of New York, it was argued that the state's taxation on property located outside its jurisdiction violated principles of interstate comity and federalism. The justice contended that a state should not have authority to tax personal property situated beyond its borders as this would lead to double taxation if other states followed suit. Furthermore, they believed such an act encroached upon the domain of Congress which has exclusive power over commerce among states under the Constitution. They also expressed concern about potential conflicts between states due to overlapping taxing jurisdictions, leading to legal chaos and confusion in determining where a corporation’s assets are actually located for tax purposes.