In the case of Wilson v. Seligman in 1891, the U.S Supreme Court ruled on a dispute involving taxation and bonds. The state of Missouri had issued bonds to fund railroad construction, which were later purchased by Seligman, a New York resident. When Missouri attempted to tax these bonds under its laws, Seligman argued that this was unconstitutional as it violated his rights under the Fourteenth Amendment's Equal Protection Clause because he was being taxed differently from Missouri residents who held similar assets. However, the court disagreed with him and upheld Missouri's right to tax out-of-state bondholders at different rates than in-state ones. The court reasoned that states have broad powers over taxation within their borders and can differentiate between residents and non-residents for such purposes without violating constitutional protections.

In the dissenting opinion for Wilson v. Seligman, Justice Lamar disagreed with the majority's ruling that a Missouri law requiring foreign corporations to pay taxes on all shares of stock owned by residents was constitutional. He argued that this violated both the Due Process and Equal Protection Clauses of the Fourteenth Amendment because it unfairly targeted out-of-state companies while exempting domestic ones from similar taxation. Furthermore, he contended that such a tax imposed an undue burden on interstate commerce as it discouraged investment in foreign corporations by Missouri residents due to increased costs associated with owning their stocks. Therefore, according to Justice Lamar, this state law should have been struck down as unconstitutional.