In the case of Standard Oil Company of California v. California in 1933, the Supreme Court ruled on a dispute about taxation between the state and an oil company. The State Board of Equalization had assessed taxes on fuel held by Standard Oil outside its refineries but within state borders, which was intended for shipment to other states or foreign countries. The company argued that this violated both their due process rights under the Fourteenth Amendment and also interfered with interstate commerce as protected by Article I, Section 8 of the Constitution. However, Justice Benjamin N Cardozo delivered a unanimous decision rejecting these claims and upholding California's right to tax such property while it remained within its jurisdiction before being shipped out-of-state or abroad.

In the dissenting opinion for Standard Oil Company of California v. California, it was argued that the majority's decision to uphold a tax on oil companies violated principles of fairness and equity. The dissenting justices believed that the tax unfairly targeted oil companies by imposing a higher burden on them than other businesses in similar circumstances. They also disagreed with the majority's interpretation of what constituted "gross receipts," arguing that this definition should not include money received from sales made outside of California or from federal lands within the state. Furthermore, they contended that upholding such a discriminatory tax would set a dangerous precedent for future cases involving interstate commerce and taxation issues.