In the case of Yazoo and Mississippi Valley Railroad Company v. Adams in 1900, the U.S Supreme Court ruled on a dispute involving taxation of railroad property. The state of Mississippi had levied taxes against the Yazoo and Mississippi Valley Railroad Company based on an assessment that included intangible assets such as franchises. The company argued this was unconstitutional under both state law and federal commerce clause protections, asserting that only tangible property should be taxed. The court held in favor of Adams (representing Mississippi), ruling that states have broad powers to tax businesses operating within their borders, including railroads. It found no constitutional issue with taxing intangibles like franchises if they are part of a business's operations within a state. This decision affirmed states' rights to levy taxes on all forms of corporate property - tangible or not - thus expanding their revenue-raising capabilities.

In the dissenting opinion for Yazoo and Mississippi Valley Railroad Company v. Adams, it was argued that the majority's decision to uphold a tax imposed by Mississippi on railroad companies operating within its borders violated principles of interstate commerce. The dissent contended that this taxation constituted an undue burden on interstate commerce as it disproportionately affected out-of-state businesses compared to in-state ones. It further asserted that such state-imposed taxes could potentially lead to retaliatory measures from other states, thereby disrupting free trade among states - a situation which federal regulation of interstate commerce is designed to prevent. The dissent also expressed concern over potential abuses of power by individual states if they were allowed unchecked authority to levy taxes on businesses involved in interstate operations without any regard for their impact on inter-state commercial activities.