In the 1918 case of Wells, Fargo & Company v. State of Nevada, the Supreme Court ruled in favor of Wells Fargo. The issue at hand was whether or not Nevada could tax property owned by Wells Fargo that was located outside state lines but used for interstate commerce within the state. The court held that such taxation violated both due process and commerce clauses under federal law as it amounted to double taxation; since other states where these properties were physically located also had a right to levy taxes on them. Therefore, according to this ruling, a state cannot impose taxes on out-of-state property used for interstate business even if some part of its operations are conducted within its jurisdiction.

In the dissenting opinion for Wells, Fargo & Company v. State of Nevada, it was argued that the majority's decision to uphold a tax imposed by Nevada on every express company doing business within its borders was incorrect. The dissenting justices believed this tax violated the Due Process Clause of the Fourteenth Amendment because it applied not only to business conducted within Nevada but also interstate commerce which is under federal jurisdiction. They contended that while states have power to regulate and control businesses operating within their boundaries, they do not possess authority over interstate commerce or operations extending beyond state lines. Therefore, imposing a tax on such activities infringes upon powers reserved for Congress alone according to the Constitution. This interpretation would protect companies from being subjected to potentially excessive taxation in multiple states for conducting nationwide operations.