In this case the majority of the court overturned First National Bank of Boston v. State of Maine, 284 U.S. 312, removing a perceived protection of the 14th Amendment from taxation by more than one state. Justice Jackson dissented on the basis that the majority opinion was not well reasoned, and arbitrarily decided. Jackson called the over turning of First National the making of the proverbial jump from the frying pan into the fire referring to the court changing their opinion on taxation being based on a person's domicile,or a company's state of incorporation. Jackson criticized this move, arguing that there should have been more analysis of what the actual effects on individuals would likely be, and from this analysis rule that a person’s domicile should be the appropriate place from which to tax.
December 27, 1942
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