Note 732 — ARTICLE I (continued 4)

He also invoked New York Central and H.R.R. Co. v. Miller, 202 U.S. 584 (1906), where although 12 to 64 per cent of the rolling stock of the railroad was outside of New York throughout the tax year, New York was nevertheless allowed to tax it all because no part was in any other State throughout the year. The case is atypical, a constitutional sport; cf. Union Refrigerator Transit Co. v. Kentucky, 199 U.S. 194 (1905).