In the case of Wisconsin et al. v. J.C. Penney Co., 1940, the U.S Supreme Court ruled in favor of J.C Penney Company, a Delaware corporation operating retail stores across various states including Wisconsin. The state had imposed an income tax on corporations based on their net income from business transacted within its borders and apportioned it according to sales made both inside and outside the state boundaries. However, J.C Penney challenged this taxation method arguing that it violated due process clause as well as interstate commerce clause by taxing extraterritorial values not attributable to any business activity within Wisconsin's jurisdiction. The court held that while a state has power to impose taxes for benefits provided such as police protection or public infrastructure, there must be clear correlation between value taxed and benefits received which was lacking in this case since part of tax was levied upon activities conducted beyond its borders with no direct benefit conferred by the State. Thus, ruling against double taxation principle where multiple jurisdictions could potentially claim right over same taxable amount without providing corresponding services or protections; thereby violating constitutional principles ensuring fair distribution of fiscal burdens among taxpayers engaged in interstate commerce.

In the dissenting opinion for Wisconsin et al. v. J.C. Penney Co., Justice Roberts argued that the state of Wisconsin did not have jurisdiction to tax a Delaware corporation like J.C. Penney, which had its principal place of business in New York and conducted mail-order operations across various states including Wisconsin. He contended that such taxation was an infringement on interstate commerce and violated the Due Process Clause of the Fourteenth Amendment as it imposed an unfair burden on out-of-state businesses by taxing them based on their gross receipts rather than net income or property value within the state's borders, thus potentially leading to multiple taxation from different states where they operate through mail orders but do not maintain physical presence or substantial nexus.