Standard Oil Co. v. Commonwealth ex rel. Allphin

MILLIKEN, Judge.

The primary issue on this appeal ' is whether this State can constitutionally levy an ad valorem tax upon the accounts and notes receivable and bank deposits of the appellant, Standard Oil Company, a Kentucky corporation, which intangibles admittedly have a business situs in other States.

The appellant, Standard Oil Company, has its home office in Louisville, Kentucky, and is engaged in the business of marketing petroleum products in five States — Kentucky, Alabama, Georgia, Mississippi and Florida. It has no refinery and no production, and its business consists of buying and…