and the tax cannot be heavy unless the profits are
large." Such a tax "constitutes one of the ordinary and general burdens
of government, from which persons and corporations otherwise subject to
the jurisdiction of the States are not exempted * * * because they
happen to be engaged in commerce among the States."[716]

Adhering to this precedent, the Court has held that a tax upon the net
income of a nonresident from business carried on by him in the State is
not a burden on interstate commerce merely because the products of the
business are shipped out of the State;[717] also that a tax which is
levied upon the proportion of the net profits of a foreign corporation
earned by operations conducted within the taxing State is valid, if the
method of allocation employed be not arbitrary or unreasonable.[718]
Where, however, the method of allocating the net income of a foreign
corporation attributed to the State an amount of income out of all
proportion to the business there transacted by the corporation, it was
held void.[719]

Also, a State may impose a tax upon the net income of property, as
distinguished from the net income of him who owns or operates it,
although the property is used in interstate commerce;[720] also a
"franchise tax" measured by the net income justly attributable to
business done by corporations within the State, although part of the
income so attributable comes from interstate and foreign commerce;[721]
also a tax on corporate net earnings derived from business done wholly
within the State may be applied to the income of a foreign pipeline
corporation which is commercially domiciled there and which pipes
natural gas into that State for delivery to, and sale by, a local
distributing corporation to local consumers.[722] Indeed it was asserted
that even if the taxpayer's business were wholly interstate commerce,
such a nondiscriminatory tax upon its net income "is not prohibited by
the commerce clause," there being no showing that the income was not on
net earnings partly attributable to the taxing State;[723] but a more
recent holding appears to contradict this position.[724]

MISCELLANEOUS TAXES AFFECTING INTERSTATE COMMERCE

Vessels

In Gloucester Ferry Company _v._ Pennsylvania,[725] decided in 1885, the
Court held inapplicable to a New Jersey corporation which was engaged
solely in transporting passengers across the Delaware River and entered
Pennsylvania only to discharge and receive passe