In the case of Youngstown Sheet & Tube Co. v. Bowers, Tax Commissioner of Ohio (1958), the U.S Supreme Court ruled in favor of Youngstown Sheet & Tube Co., a company that had challenged an Ohio state tax law. The company argued that it was unconstitutional for them to be taxed on goods produced in Ohio but stored temporarily out-of-state before being shipped back into Ohio for sale or use. The court agreed with this argument, stating that such taxation violated the Due Process Clause and Commerce Clause of the Constitution as it amounted to extraterritorial taxation - taxing property outside its jurisdictional boundaries without providing any benefits or protections in return. This decision reinforced constitutional limitations on states' power to tax interstate commerce and established important precedents regarding due process rights and state taxation powers.

In the dissenting opinion for Youngstown Sheet & Tube Co. v. Bowers, Justice Brennan disagreed with the majority's decision that Ohio's tax on gross receipts did not violate the Commerce Clause of the U.S Constitution. He argued that this taxation system placed an unfair burden on interstate commerce and was therefore unconstitutional. In his view, a state should only be able to impose taxes on activities within its own borders and not those occurring across state lines as it could lead to multiple states taxing the same transaction, creating an undue burden on interstate commerce. Furthermore, he believed that such a tax system would discourage businesses from operating in more than one state due to potential double taxation issues.