Ayer & Lord Tie Co. v. State of Kentucky
In Ayer & Lord Tie Co. v. State of Kentucky, 202 U.S. 409 (1906), the Supreme Court had occasion to consider the taxation of vessels plying between the ports of different States, and it was held that where a vessel has acquired an actual situs in a State other than that which is the domicile of the owner, it may be taxed, because it is within the jurisdiction of the taxing authority, and, after reviewing the previous cases in this court, Mr. Justice White, speaking for the court, said (p. 423):
"But, if enrollment at that place was within the statutes, it is wholly immaterial, since the previous decisions to which we have referred decisively establish that enrollment is irrelevant to the question of taxation, because the power of taxation of vessels depends either upon the actual domicil of the owner or the permanent situs of the property within the taxing jurisdiction."
In Ayer & Lord Tie Co. v. Kentucky, 202 U. S. 409, 421 (1906), the Supreme Court said:
"The general rule has long been settled as to vessels plying between the ports of different States, engaged in the coastwise trade, that the domicil of the owner is the situs of a vessel for the purpose of taxation, wholly irrespective of the place of enrollment, subject, however, to the exception that where a vessel engaged in interstate commerce has acquired an actual situs in a State other than the place of the domicil of the owner, it may there be taxed because within the jurisdiction of the taxing authority."