The U.S. Supreme Court case Security Trust and Safety Vault Company v. City of Lexington in 1906 revolved around the issue of taxation on shares held by a trust company. The city of Lexington, Kentucky had imposed taxes on the shares owned by Security Trust and Safety Vault Company, which was based in another state but did business within Lexington's jurisdiction. The company argued that this tax violated their rights under the Fourteenth Amendment as it constituted double taxation since they were already taxed at their home base for these same assets. However, the court ruled against them stating that there is no constitutional prohibition against taxing property located within a state’s borders simply because it may also be taxed elsewhere; thus upholding Lexington's right to impose such taxes. This decision reinforced states' authority to levy taxes on out-of-state businesses operating within their jurisdictions.

The dissenting opinion in the case of Security Trust and Safety Vault Company v. City of Lexington argued that the majority's decision was a departure from established principles regarding tax exemption. The dissent emphasized that exemptions should be strictly construed, with any doubts resolved against it. They disagreed with the interpretation that an agreement between two parties could bind future legislatures to maintain a perpetual tax exemption for certain properties, asserting such agreements were not within their power to make. Furthermore, they pointed out inconsistencies in applying this principle across different cases and warned about potential implications on public finance if private corporations could secure permanent tax exemptions through contracts with local governments.