Limitations of the Taxing Power, Including Limitations Upon Public Indebtedness; a Treatise Upon the Constitutional Law Governing Taxation And the Incurrence of Public Debt in the United States, in the Several States, And in the Territories

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232-237, 33 L. ed. 892, U. S. 134, 40 L. ed. 645, 16 Sup. Ct.
10 Sup. Ct. Rep. 533 : Tennessee v. R«p. 456 ; Home Ins. Co. v. New York^ Whitworth, 117 U. S. 129, 136, 137, 134 U. S. 594, 33 L. ed. 1025, 10 Sup.
20 L. ed. 830, 6 Sup. Ct. Rep. 645 ; Ct. Rep. 593.
[874] DOUBLE TAXATION. 675 on the value of his property, without deduction for debts. Assume a simple illustration : A has property worth $1,000, B has nothing.
B buys A's property, giving in payment his note for $1,000. The state taxes
...A on the note which he owns, and B on the prop- erty which he has. Thus, although in fact there is but $1,000 worth of property, taxes on a valuation of $2,000 are paid with respect to it.
Another common case is where a corporation is taxed on its prop- erty, while its shares, which represent the same property, are taxed to the shareholders.
1362. Supporting the general proposition that duplicate taxa- tion is not constitutionally objectionable in states where there is no express requirement of equality and uniformity, are the cases here cited.


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