[592] 222 U.S. 210 (1911).
[593] 233 U.S. 16 (1914).
[594] Ibid. 23. See also Superior Oil v. Mississippi ex rel. Knox, 280 U.S. 390 (1930).
[595] Chassaniol v. Greenwood, 291 U.S. 584 (1934).
[596] Wiloil Corp. v. Pennsylvania, 294 U.S. 169, 173 (1935); see also Minnesota v. Blasius, 290 U.S. 1 (1933).
[597] 309 U.S. 33 (1940).
[598] Best & Co. v. Maxwell. 311 U.S. 454, 455 (1940).
[599] 300 U.S. 577 (1937). Cf. Hinson v. Lott, 8 Wall. 148 (1869). Here was involved a tax of fifty cents per gallon on all spiritous liquors brought into the State. Comparing the tax with a similar one imposed upon liquors manufactured in the State, the Court upheld the statute. "The taxes were complementary and were intended to effect equality."
[600] 300 U.S. at 583-584. Some subsequent use tax cases in the Henneford pattern are the following: Bacon & Sons v. Martin was decided in a unanimous per curiam opinion. It involved a Kentucky statute which imposed a tax "on the 'receipt' of cosmetics in the State by any Kentucky retailer" equal to twenty per cent of the invoice price plus transportation cost, if any to the Kentucky dealer. The Kentucky court held that "the imposition of the tax against the retailer is not on the act of receiving the cosmetics, but on the sale and use thereof, after the retailer has received them." On this interpretation the Supreme Court sustained the tax. Obviously, other things being equal, there is little difference between a tax on receiving and a tax on possession a moment later. 305 U.S. 380 (1939). In Felt & Tarrant Manufacturing Co. v. Gallagher, 306 U.S. 62 (1939), a California use tax was upheld applicable to a nonresident corporation which solicited orders from California purchasers through agents for whom it hired offices in the State and took orders subject to the vendor's approval. In Nelson v. Sears, Roebuck & Company and Nelson v. Montgomery Ward & Company, 312 U.S. 359 and 373 (1941) it was held that a foreign corporation which maintained retail stores in Iowa could be validly required to collect an Iowa use tax in respect of mail orders sent by Iowa purchasers to out-of-state branches of the corporation and filled by direct shipment by mail or common carrier from those branches to the purchasers. In General Trading Company v. State Tax Commission, 322 U.S. 335 (1944), also involving the Iowa tax, it was held that a company carrying on no operations in Iowa other than the solicitation of orders by traveling salesmen was liable for collection of the tax on goods sold to Iowa residents, even though the corporation was not licensed to do business in the State and the orders were forwarded for acceptance to Minnesota where they were filled by direct shipment to Iowa customers.
[601] 309 U.S. 33 (1940).