In the case of State Tax Commission of Mississippi et al. v. Interstate Natural Gas Co., Inc., 1931, the U.S Supreme Court ruled in favor of Interstate Natural Gas Company (INGC). The court held that INGC was not liable to pay taxes imposed by the state tax commission for transporting gas through pipelines across states as it did not have a permanent business presence or property in Mississippi. The court reasoned that interstate commerce is under federal jurisdiction and cannot be taxed by individual states unless there's substantial nexus between the state and taxpayer’s activities within its borders. This decision established an important precedent regarding taxation on interstate commerce, emphasizing that businesses must have significant connections with a state before they can be subjected to its taxing powers.

In the dissenting opinion for the case of State Tax Commission of Mississippi et al. v. Interstate Natural Gas Co., Inc., it was argued that the majority's decision to strike down a tax imposed by Mississippi on natural gas transported through pipelines in its territory, but sold and consumed out-of-state, contradicted previous rulings upholding similar taxes. The dissent emphasized that such taxes were not discriminatory or burdensome to interstate commerce as they applied equally to all companies transporting gas through pipelines within state borders, regardless of where it was ultimately sold or used. Furthermore, they contended that states should have authority over their own resources and be able to levy reasonable taxes on businesses operating within their jurisdiction without interference from federal courts unless there is clear evidence these measures violate constitutional principles protecting interstate commerce.