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Joy Oil Co., Ltd. v. State Tax Commission, 337 U.S. 286 (1949)

Joy Oil Co., Ltd. v. State Tax Commission

No. 223

Argued January 7, 1949

Decided June 13, 1949

337 U.S. 286


Petitioner, Canadian corporation, purchased in Michigan 1,500,000 gallons of gasoline, certified that it was purchased for export, hipped it by rail to Detroit under bills of lading marked "For Export to Canada," and placed it in storage tanks in Dearborn, Michigan. Fifteen months later, when only 50,000 gallons had been exported to Canada, Dearborn assessed an ad valorem property tax on the remaining gasoline. Because of a shortage of shipping space, it was more than eighteen months after storage before all of the gasoline had been exported to Canada.

Held: the tax was not in violation of the Export-Import Clause, Art. I, § 10, cl. 2, of the Federal Constitution. Pp. 337 U. S. 286-289.

321 Mich. 335, 32 N.W.2d 472 affirmed.

An ad valorem tax assessed by a Michigan municipality upon a Canadian corporation's stores of gasoline was sustained by the State Supreme Court against a claim of invalidity under the Export-Import Clause of the Federal Constitution. 321 Mich. 335, 32 N.W.2d 472. This Court granted certiorari. 335 U.S. 812. Affirmed, p. 337 U. S. 289.

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