In the case of Standard Pipe Line Company v. Miller County Highway & Bridge District, 1927, the Supreme Court was asked to determine whether a county highway district in Arkansas had the authority to levy taxes on oil pipelines that crossed through its jurisdiction. The pipeline company argued that it should not be subject to these taxes because it was an interstate business and therefore only subjectable to federal regulation under the Commerce Clause of the Constitution. However, after reviewing previous cases and legal principles related to taxation and commerce clause jurisprudence, the court ruled against Standard Pipe Line Company. It held that while Congress has exclusive power over interstate commerce, this does not prevent states from exercising their traditional taxing powers unless such exercise directly interferes with congressional regulations or burdens interstate commerce excessively. Therefore, as long as state tax laws do not discriminate against or place undue burden on interstate businesses compared with intrastate ones they are generally permissible.

The dissenting opinion in the case of Standard Pipe Line Company v. Miller County Highway & Bridge District argued that the majority's decision to allow a county highway district to tax an interstate pipeline company was inconsistent with previous rulings and violated principles of federalism. The dissenters contended that, as an interstate business, the pipeline company should only be subject to taxation by states where it had a physical presence or conducted substantial business activities. They further asserted that allowing local entities such as counties or districts to impose taxes on such companies would lead to excessive and potentially discriminatory taxation, undermining national economic unity and efficiency. Moreover, they disagreed with the majority's interpretation of "property" for tax purposes; arguing instead that intangible assets like franchise rights could not be considered property within any particular state unless used there in some significant way.