[108] Kirtland _v._ Hotchkiss, 100 U. S., 491 (1879). [109] Kirtland _v._ Hotchkiss, _supra_. Thus, “If the law treats the mortgagee’s interest in the land as real estate for his protection, it is not easy to see why the law should forbid it to be treated as real estate for the purpose of taxation.” Savings and Loan Society _v._ Multnomah County, 169 U. S., 421 (1898). [110] McCulloch _v._ Maryland, _supra_, quoted in The Collector _v._ Day, 11 Wallace, 113 (1870). [111] The Collector _v._ Day, _supra_. (The Court quotes the Tenth Amendment, in this connection, as the basis of its decision.) [112] _Idem._ [113] The Collector _v._ Day, _supra_. [114] _Id._ [115] The Collector _v._ Day, _supra_. [116] _Id._ [117] Amendment XVI. [118] Compare the effect of the Thirteenth Amendment, the Fourteenth and Fifteenth Amendments on the decision of the Supreme Court in Scott _v._ Sandford, 19 Howard, 393 (1857). [119] To what extent a salaried official of a State is exempt from inclusion of his salary as income taxable under the Sixteenth Amendment is as yet not determined by judicial decision. “The corporate franchises, the property, the business, the income of corporations created by a State may undoubtedly be taxed by the State; but in imposing such taxes care should be taken not to interfere with or hamper, directly or by indirection, interstate or foreign commerce, or any other matter exclusively within the jurisdiction of the Federal government. This is a principle so often announced by the courts, and especially by this court (the Supreme Court of the United States) that it may be received as an axiom of our constitutional jurisprudence.” Philadelphia and Southern Steamship Company _v._ Pennsylvania, 122 U. S., 326 (1887). [120] United States _v._ R. R. Co., 17 Wallace, 322 (1873). [121] See the Chapter on _The Law of Fundamental Rights_, _post_. [122] Wisconsin Central R. R. Co. _v._ Price County, 133 U. S., 496 (1890). As to exemptions, the decisions are conflicting. Not infrequently notices may be seen of exemption of manufacturing plants, or other industrials, from taxation, if they locate within a community. Mississippi in its constitution of 1890 made such exemptions by special ordinance. Such exemption has been held valid in Franklin Needle Co. _v._ Franklin, 65 N. H., 177; Florida Central Railway Co. _v._ Reynolds, 183 U. S., 476; _Per contra_, Brewer Brick Co. _v._ Brewer, 62 Maine, 62. [123] Loan Association _v._ Topeka, 20 Wallace, 655 (1874); Kingman _v._ City of Brockton, 153 Mass., 255 (1891); an admirable note citing decisions as to a good tax may be found in L. B. Evans, _Leading Cases on American Constitutional Law_ (Ed. 1916), p. 211. [124] Art. i., 2: 3; 8: 1.