Note 641 — ARTICLE I (continued 3)

245 U.S. 178 (1917). Cf. Baltic Mining Co. v. Massachusetts, 231 U.S. 68 (1914); Kansas City Ry. v. Kansas, 240 U.S. 227 (1916); and Kansas City, M. & B.R. Co. v. Stiles, 242 U.S. 111 (1916). In each of these a tax like that involved in Looney v. Crane was sustained, in the first two because the statute set a maximum limit to the tax; in the third because the amount collected under the act was held to be "reasonable." The ideology of these decisions is clearly opposed to that of the cases treated in the text. The rule in Looney v. Crane Co. was held not applicable in the case of a West Virginia corporation doing business in Illinois and owning practically all of its property there. An Illinois tax on the local business, which was measured by the total capitalization of the company was sustained, it being shown further that the tax was little more than it would have been if levied at the same rate directly on the property of the company that was in Illinois. Hump Hairpin Mfg. Co. v. Emmerson, 258 U.S. 290 (1922).