Page:Federal Reporter, 1st Series, Volume 2.djvu/897

 890 F£DEBAIi BEPOSTEB. �gible property of such company or aBsociation, is a general law, or that it is unif orm as to the elass upon which it operates. It is not restricted to any particular part of the state, nor is it limited to a special tax. It extends to the entire state, for the purpose of general taxation, and it applies the same rule to ail within the class upon which it operates — namely, the corpo- rations now or hereafter created under the laws of this state. It is not required, as seems to be thought by some of the counsel with whose arguments we have been favored, that the legislature shall, in providing for the taxation of corpora- tions, under the last clause of the section referred to, desig- nate the precise amount which the corporation shall pay, and that this shall be the same on each corporation, without re- gard to the value of the franchise or privileges enjoyed, nor that Buch taxation shall be of like character with that which may be imposed on innkepers and others pursuing the particular vocations named. It is only required that they shall be taxed in such manner as the general assembly shall, from time to time, direct by general law, and the only uniformity required is as to the class upon which such general law shall operate. It is, therefore, left entirely to the legislature to determine whether corporations shall be taxed only on their tangible property, on the amount of their capital paid in, on the amount of their gross reeeipts, or, as in the present in- stance, on the value of their tangible property, and on the fair cash value of their capital stock, including their fran- chises, over and above the assessed value of their tangible property, subject merely to the limitation that it shall be directed by general law, uniform as to the class upon which it operates. " �And the rule fairly deducible from these cases, I think, is that the power of the legislature is not only plenary as to the manner in which the property and franchises of corpora- tions created by the state shall be taxed, but it can also clas- sify such corporations for the purpose of taxation — that is, it can provide a mode of fixing the value of the franchises or capital stock of railroad corporations, anotlier for mining cor- porations, and another for manufacturing companies ; and I ����