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State v. Stoll was a United States Supreme Court case that addressed the issue of whether a state can impose a tax on a non-resident's income from property located within the state. The case involved a dispute between the State of Wisconsin and a non-resident, John Stoll, who owned property in Wisconsin. The state had imposed a tax on Stoll's income from the property, and Stoll argued that the tax was unconstitutional. The Supreme Court held that the tax was constitutional, finding that the state had the power to impose a tax on the income of non-residents from property located within the state. The Court reasoned that the power to tax was an essential part of the state's sovereignty, and that the state had the right to impose taxes on non-residents in order to protect its citizens and promote the general welfare. The Court also noted that the tax was not discriminatory, as it applied equally to all non-residents regardless of their residence. In conclusion, the Supreme Court held that the state had the power to impose a tax on the income of non-residents from property located within the state. The Court found that the tax was not discriminatory and was necessary to protect the citizens of the state and promote the general welfare.
Justice Field delivered the dissenting opinion in State v. Stoll, arguing that the majority's decision was contrary to established precedent and would lead to a dangerous expansion of state power. He argued that the Court had previously held that states could not tax federal bonds or other obligations issued by Congress, as such taxation would be an unconstitutional interference with congressional authority over national finances. The majority opinion sought to distinguish this case from prior cases on similar issues by noting that it involved a state-issued bond rather than one issued by Congress; however, Justice Field disagreed with this distinction and noted its potential implications for future cases involving taxation of federal securities. He further argued that if states were allowed to impose taxes on federally-issued bonds without violating constitutional principles then they could also interfere with other areas traditionally reserved for exclusive control by Congress - such as foreign affairs and interstate commerce - which he viewed as unacceptable under any interpretation of the Constitution.