United States Fidelity & Guaranty Co. v. City of Spartanburg

Brailsford, Justice:

The troublesome question on this appeal is whether the Business License Ordinance of the City of Spartanburg imposed a palpably unreasonable and irrational tax on the appellant, United States Fidelity and Guaranty Company, and others of its class, for the privilege of writing fire and casualty insurance in the City in 1971 and 1972, thus depriving appellant of equal protection of the law. In appellant’s action to recover license taxes for these years paid under protest, the circuit court sustained the validity of the ordinance.

The following comparison between the tax…