Joy Oil Co., LTD. v. State Tax Commission (337 U.S. 286)
U.S. Supreme Court · decided June 13, 1949 · Supreme Court Database (Spaeth)
- Citation
- 337 U.S. 286 · 69 S. Ct. 1075
- Decided
- June 13, 1949
- Term
- October Term 1948
- Vote
- 6–3
- Majority author
- Justice Frankfurter
- Issue area
- Economic Activity
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Liberal
Opinion excerpt
Mr. Justice Frankfurter delivered the opinion of the Court. On December 29, 1945, petitioner Joy Oil Company, Ltd., a Canadian corporation, purchased 1,500,000 gal-Ions of gasoline from Mid-West Refineries, Inc., of Grand Rapids, Michigan. The bills of lading issued by the railroad to which the gasoline was delivered were marked “For Export to Canada,” but the gasoline was consigned to petitioner at Detroit. In order to secure the benefits of lower export freight rates and exemption from the federal transportation and manufacturers’ excise taxes, petitioner furnished Mid-West Refineries and the railroad with prescribed forms certifying that the gasoline was purchased for export. Rail shipments' were begun in January and completed in February of 1946. As the gasoline reached Detroit it was accumulated in storage tanks leased by petitioner at Dearborn. On April 1, 1947, the city of Dearborn assessed an ad valorem property tax on the gasoline, all of which, except 60,000 gallons, shipped to Canada by truck over the Ambassador Bridge, had then been in the Dearborn tanks for fifteen months. Shipment by truck was halted by a federal regulation prohibiting the transportation of inflammables over any international bridge, and petitioner apparently chose not to ship the gasoline by rail across the Detroit River. Iru July of 1947 petitioner began to ship it to Canada by water; the last…
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