In the 1945 case of Wilson et al., Doing Business as Wilson Lumber Co. v. Cook, Commissioner of Revenue, the U.S Supreme Court ruled in favor of Cook, upholding a tax assessment on lumber companies in Alabama. The plaintiffs (Wilson and others) argued that their business was unfairly taxed compared to other businesses due to an amendment made by the state legislature which imposed taxes based on the amount of timber cut from land owned or controlled by them during each year rather than taxing them like other corporations based on capital stock value. They claimed this violated equal protection under law guaranteed by Fourteenth Amendment since it created a separate class for taxation purposes without any reasonable basis for such classification. However, the court held that there was no violation because states have wide discretion when creating classifications for tax purposes provided they are not arbitrary or discriminatory; here it found sufficient grounds existed justifying different treatment given nature and operation characteristics unique to lumber industry.

In the dissenting opinion for Wilson et al., Doing Business as Wilson Lumber Co. v. Cook, Commissioner of Revenue, it was argued that the majority's decision to uphold a tax on lumber companies' gross receipts from sales outside of Alabama violated the Commerce Clause of the U.S. Constitution by imposing an undue burden on interstate commerce. The dissent contended that this ruling effectively allowed states to impose tariffs on goods produced within their borders but sold elsewhere, which would disrupt and distort national economic activity in violation of federal law and policy favoring free trade among states. It further suggested that such taxes could lead to retaliatory measures by other states and potentially ignite "trade wars" detrimental to overall national welfare.