"Not only may the power to tax be exercised oppressively, but for one government--state or national--to lay a tax on the instrumentalities or securities of the other is derogatory to the latter's dignity, subversive of its powers, and repugnant to its paramount authority.  See California Central P.R. Co., 127 U.S. 1, 41,  8 S.Ct. 1073 (32 L.Ed. 150).  These constitute special and compelling reasons why courts, in scrutinizing taxing acts like that here involved, should be acute to distinguish between an exaction which is substance and reality is what it pretends to be, and a scheme to lay a tax upon a nontaxable subject by a deceptive use of words."  [Macallen Co. v. Commonwealth of Massachusetts, 279 U.S. 620, 49 S.Ct. 432 (1929)]

Copyright Family Guardian Fellowship