What is the test for determining whether the state has the power to impose additional taxes on a franchise?

MultiRegion, United States of America

The following excerpt is from Sunset Tel. & Tel. Co. v. City of Pomona, 164 F. 561 (9th Cir. 1908):

San Francisco v. Western U. Tel. Co., 96 Cal. 151, 31 P. 10, 17 L.R.A. 301, simply determines that, under the facts of that case, a tax upon its franchise in addition to the taxes which complainant pays upon its property in common with others, was beyond the power of the state, and said case has but little bearing upon the point now under consideration.

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