[712] 335 U.S. 80.
[713] 337 U.S. 662, 666, 677-678, 680.
[714] See supra, pp. [196], [204-207].
[715] 247 U.S. 321 (1918).
[716] Ibid. 328-329.
[717] Shaffer v. Carter, 252 U.S. 37 (1920).
[718] Underwood Typewriter Co. v. Chamberlain, 254 U.S. 113 (1920); Bass, Ratcliff & Gretton v. State Tax Commission, 266 U.S. 271 (1924).
[719] Hans Rees' Sons v. North Carolina, 283 U.S. 123, 132, 133 (1931). In this case a North Carolina tax was assessed on the income of a New York corporation, which bought leather, manufactured it in North Carolina, and sold its products at wholesale and retail in New York. The Court observed: "The difficulty of making an exact apportionment is apparent and hence, when the State has adopted a method not intrinsically arbitrary, it will be sustained until proof is offered of an unreasonable and arbitrary application in particular cases." The decisions in the Underwood and Bass cases, supra, "are not authority for the conclusion that where a corporation manufactures in one State and sells in another, the net profits of the entire transaction, as a unitary enterprise, may be attributed, regardless of evidence, to either State."
[720] Atlantic Coast Line v. Daughton, 262 U.S. 413 (1923).
[721] Matson Nav. Co. v. State Board, 297 U.S. 441 (1936). See also Butler Bros. v. McColgan, 315 U.S. 501 (1942), where the tax was sustained under the Fourteenth Amendment.