[563] Shaffer v. Carter, 252 U.S. 37 (1920); Travis v. Yale & T. Mfg. Co., 252 U.S. 60 (1920).
[564] New York ex rel. Cohn v. Graves, 300 U.S. 308 (1937).
[565] Maguire v. Trefry, 253 U.S. 12 (1920).
[566] Guaranty Trust Co. v. Virginia, 305 U.S. 19, 23 (1938).
[567] Whitney v. Graves, 299 U.S. 366 (1937).
[568] Underwood Typewriter Co. v. Chamberlain, 254 U.S. 113 (1920); Bass, Ratcliff & Gretton v. State Tax Commission, 266 U.S. 271 (1924).
[569] Hans Rees' Sons v. North Carolina, 283 U.S. 123 (1931).
[570] Matson Nav. Co. v. State Board, 297 U.S. 441 (1936).
[571] Wisconsin v. J.C. Penney Co., 311 U.S. 435, 448-449 (1940). Dissenting, Justice Roberts, along with Chief Justice Hughes and Justices McReynolds and Reed, stressed the fact that the use and disbursement by the corporation at its home office of income derived from operations in many States does not depend on, and cannot be controlled by, any law of Wisconsin. The act of disbursing such income as dividends, he contended, is "one wholly beyond the reach of Wisconsin's sovereign power, one which it cannot effectively command, or prohibit or condition." The assumption that a proportion of the dividends distributed is paid out of earnings in Wisconsin for the year immediately preceding payment is arbitrary and not borne out by the facts. Accordingly, "if the exaction is an income tax in any sense it is such upon the stockholders [many of whom are nonresidents] and is obviously bad."—See also Wisconsin v. Minnesota Mining Co., 311 U.S. 452 (1940).
[572] Great A. & P. Tea Co. v. Grosjean, 301 U.S. 412 (1937).