It would appear that the same rules apply to the state taxation of net receipts of companies doing an interstate commerce business as govern in the case of the taxation of gross receipts. It may, however, be observed, that should the court seek to justify the taxation of receipts by an assumption that they have, when taxed, become a part of the property of the companies receiving them, as was, for example, asserted in State Tax on Railway Gross Receipts,27 the argument is especially strong as to net receipts. It is believed, however, that the courts will not in the future place any reliance upon this argument which is, at its best, an exceedingly weak one.28