prevent a State from taxing a resident citizen who
engaged in a general commission business, on the profits thereof,
although the business consisted "for the time being, wholly or partially
in negotiating sales between resident and nonresident merchants, of
goods situated in another State."[589] Also, it has been held that a
stamp tax on transfers of corporate stock, as applied to a sale between
two nonresidents, of the stock of foreign railway corporations, was not
an interference with interstate commerce.[590] Likewise, the business of
taking orders on commission for the purchase and sale of grain and
cotton for future delivery not necessitating interstate shipment was
ruled not to be interstate commerce, and as such exempt from taxation,
although deliveries were sometimes made by interstate shipment.[591] And
in Banker Bros. Co. _v._ Pennsylvania[592] it was held that a tax upon a
domestic corporation selling automobiles built by a foreign corporation
under an arrangement by which the latter agreed to build for and sell to
the former, for cash, at a specified price less than list price, was not
a tax on interstate transactions, there being nothing which connected
the ultimate buyer with the manufacturer but a warranty and the buyer's
agreement to pay the list price f.o.b. factory. Similarly, in Browning
_v._ Waycross[593] it was held that the business of erecting lightning
rods within the limits of a town by the agent of a nonresident
manufacturer on whose behalf such agent had solicited orders for the
sale of the rods, and from whom he had received them when shipped into
the State, was validly subjected to a municipal license tax. "It was
not," said the Court, "within the power of the parties by the form of
their contract to convert what was exclusively a local business, * * *,
into an interstate commerce business * * *"[594] Also, a municipal
license tax upon persons engaged in the business of buying or selling
cotton for themselves was found not to impose a forbidden burden upon
interstate commerce even though the cotton was purchased with a view to
ultimate shipment in some other State or country.[595] Nor was a
gallonage tax imposed by a State upon a distributor of liquid fuel
rendered repugnant to the commerce clause by the fact that the
distributor caused fuel sold to customers in the State to be shipped
from another State for delivery in tank cars--"deemed original
packages"--on purchaser's siding, as agreed.