Tennessee v. Pullman Southern Car Company was a United States Supreme Court case that addressed the issue of whether a state could tax a company that was incorporated in another state. The case involved the Pullman Southern Car Company, which was incorporated in Illinois, but had a branch in Tennessee. Tennessee attempted to impose a tax on the company, but the company argued that it was not subject to the tax because it was incorporated in Illinois. The Supreme Court held that the state of Tennessee could not impose a tax on the Pullman Southern Car Company because it was incorporated in Illinois. The Court reasoned that the company was not subject to the jurisdiction of Tennessee, and therefore could not be taxed by the state. The Court also noted that the company was not engaged in any activities in Tennessee that would make it subject to the state's jurisdiction. The Court concluded that the tax was unconstitutional and could not be imposed on the company.

In Tennessee v. Pullman Southern Car Company, the Supreme Court was asked to decide whether a state tax on railroad cars violated the Constitution's Commerce Clause. The majority opinion held that it did not, but Justice Field dissented from this decision. He argued that while states have broad authority to impose taxes within their borders, they cannot do so in such a way as to interfere with interstate commerce or burden it disproportionately compared with intrastate commerce. In this case, he believed that Tennessee had done just that by taxing all railcars entering its borders regardless of where they were coming from and how long they would remain there; thus placing an undue burden on out-of-state companies who must pay the same rate as local businesses even if their cars are only passing through for a short period of time before continuing elsewhere. As such, he concluded that the tax should be struck down as unconstitutional under the Commerce Clause and urged his colleagues to reconsider their ruling in future cases involving similar issues.