In the case of Union Tank Line Company v. Wright, Comptroller General of Georgia in 1918, the Supreme Court ruled on a dispute involving taxation and interstate commerce. The Union Tank Line Company was an Ohio-based corporation that owned tank cars used for transporting oil across state lines. The company argued that Georgia's tax on its property within the state violated the Commerce Clause of the U.S Constitution because it interfered with interstate commerce. However, Georgia contended that as long as their taxes were not discriminatory or excessively burdensome to out-of-state businesses, they had every right to impose them. The Supreme Court sided with Georgia ruling that states have broad powers under their police and taxing authorities unless explicitly limited by federal law or constitutionally prohibited from doing so. It held that there is no constitutional impediment preventing a state from imposing a tax upon personal property located within its borders even if such property is employed in interstate commerce.

In the dissenting opinion for Union Tank Line Company v. Wright, it was argued that Georgia's tax on foreign corporations doing business within its borders did not violate the Commerce Clause of the U.S. Constitution. The dissenting justices believed that this case should have been decided based on precedent set by previous cases such as Western Union Telegraph Co. v. Kansas and Pullman Co. v. Kansas, in which similar state taxes were upheld by the Supreme Court despite challenges under the Commerce Clause and Fourteenth Amendment due process clause respectively. The dissenters contended that a state has every right to impose conditions upon foreign corporations seeking to do business within its jurisdiction, including taxation - provided these conditions do not interfere with federal authority or infringe upon constitutional rights of those entities. They further noted that while interstate commerce is indeed a matter of federal concern, it does not render states powerless in regulating or taxing activities occurring within their boundaries even if they involve interstate transactions. Therefore, according to them, Georgia’s imposition of an annual license tax on out-of-state companies like Union Tank Line Company was constitutionally valid as long as it wasn't discriminatory against interstate commerce nor deprived businesses from their property without due process.