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Fargo v. Hart
United States Supreme Court
193 U.S. 490, 24 S. Ct. 498 (1904)
The American Express Company was a New York corporation that did business in Indiana. American Express delivered mail to recipients across the United States and internationally. American Express owned real estate and personal property worth approximately $22 million, $8,000 worth of which was located in Indiana. American Express paid state taxes in Indiana on the $8,000 worth of property. The Indiana Board of Tax Commissioners (the board) (defendant) attempted to apply Indiana’s property tax to American Express’s business as a whole rather than only to the property located in Indiana. To do so, the board calculated the proportion of American Express’s business that was allocable to Indiana by determining the ratio of mileage that the company traveled in Indiana to the company’s total mileage, minus miles traveled on the ocean for international deliveries. The board defended its tax scheme by arguing that all of American Express’s property is necessarily used by the company as a whole. J. C. Fargo (plaintiff), the president of American Express, filed a lawsuit against the board in federal court seeking to enjoin the board from assessing the additional property taxes against American Express. The circuit court dismissed Fargo’s complaint, and Fargo appealed.
Rule of Law
Holding and Reasoning (Holmes, J.)
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