In the 1934 case of Wiloil Corporation v. Pennsylvania, the U.S. Supreme Court ruled in favor of Pennsylvania, upholding its right to tax a foreign corporation for conducting business within state borders. The Wiloil Corporation was incorporated in Delaware but had an office and conducted operations in Pennsylvania where it bought and sold oil leases and royalties. The company argued that these transactions were interstate commerce, which would make them exempt from state taxation under federal law at that time. However, the court disagreed with this argument stating that while buying and selling oil leases could be considered as part of interstate commerce when done across state lines; maintaining an office for such transactions within a single state constituted doing business there - thus subjecting it to local taxes even if all sales were made out-of-state or abroad. The ruling clarified how states can levy taxes on corporations operating within their jurisdiction regardless of whether they are domestic or foreign entities.

In the dissenting opinion for Wiloil Corporation v. Pennsylvania, the justice argued that the state of Pennsylvania had no right to impose a tax on an out-of-state corporation's gross receipts from interstate commerce. The justice contended that such taxation was in direct violation of the Commerce Clause of the U.S Constitution which gives Congress exclusive power over interstate commerce. They believed this clause prohibits states from imposing taxes or regulations that would interfere with or discriminate against interstate commerce, and thus found it unconstitutional for Pennsylvania to levy a tax on Wiloil Corporation's gross receipts derived entirely from its operations outside of Pennsylvania. Furthermore, they disagreed with majority’s view about due process not being violated as they felt taxing income generated by activities conducted wholly beyond a state’s borders infringes upon rights guaranteed under Due Process Clause.