Note 691 — ARTICLE I (continued 3)

Lockhart, Gross Receipts Taxes on Interstate Transportation and Communication, 57 Harvard L. Rev. 40, 65, 66 (1943); Galveston, H. & S.A.R. Co. v. Texas, 210 U.S. 217 (1908); New Jersey Bell Teleph. Co. v. State Bd. of Taxes and Assessments, 280 U.S. 338 (1930). But Cf. Nashville, C. and St. L. Ry. v. Browning, 310 U.S. 362 (1940). In both the Galveston and New Jersey Telephone Company cases, although the taxable events all occurred within the taxing State, the possibility of multiple taxation was nevertheless present. See also Puget Sound Stevedoring Co. v. State Tax Commission, 302 U.S. 90 (1937), the decision in which might have been rested upon the clause of the Constitution forbidding the States to tax exports. See also Richfield Oil Corp. v. State Board of Equalization, 329 U.S. 69 (1946).