National Distillers Products Corporation was incorporated in Virginia and maintained its principal place of business in New York.

The Ohio Tax Commissioner assessed ad valorem taxes on accounts receivable derived from shipments originating from Ohio manufacturing plants belonging to Wheeling Steel Corporation and National Distillers Products Corporation on the grounds that such accounts "result from the sale of property from a stock of goods maintained within the state.

The court held that the ad valorem tax assessed against the accounts receivable of these corporations violated the Equal Protection Clause of the 14th Amendment.

The court declined to address the issue of whether Ohio violated the Due Process Clause in assessing this tax.

Mr. Justice Douglas is troubled by the notion that corporations are to be classified as people for the purpose of interpreting the Equal Protection Clause.