In the United States Supreme Court case of United Zinc & Chemical Company v. Britt et al., 1921, the court examined whether a state could impose taxes on an out-of-state corporation's property located within its borders without violating due process rights. The plaintiff, United Zinc & Chemical Company, was incorporated in New Jersey but owned and operated a plant in Oklahoma where it processed zinc ore into metallic zinc. The State of Oklahoma imposed ad valorem taxes on both the real estate and personal property at this location which included raw materials stored for processing as well as finished products awaiting shipment to customers outside of Oklahoma. The company argued that these goods were part of interstate commerce and therefore exempt from local taxation under federal law. However, the Supreme Court disagreed with this argument stating that until such time as they actually entered transit or were committed to be transported out-of-state, they remained subject to local taxation because their presence contributed value to the company’s business operations within Oklahoma. Thus, by ruling against United Zinc & Chemical Co., this landmark decision established precedent for states' ability to tax certain properties belonging to foreign corporations operating within their jurisdiction.

The dissenting opinion in the case of United Zinc & Chemical Company v. Britt et al., 1921, argued that the majority's decision to uphold a lower court ruling against United Zinc was incorrect. The dissent contended that there was insufficient evidence to prove negligence on part of the company for causing harm due to pollution from its smelter operations. It also disagreed with the majority's interpretation and application of nuisance law, arguing that it should not be applied so broadly as to include industrial activities such as those carried out by United Zinc. Furthermore, it expressed concern about potential economic implications if businesses could be held liable for damages caused by their normal operations without clear proof of negligence or intent.