The question is whether there is anything in the Constitution, or inherent in the nature of an excise, which requires that it should be charged only upon goods manufactured or grown after the imposition of the excise.

I am clearly of opinion that there is not. The power of the Parliament to make laws with respect to 'taxation' is unlimited, except by the condition that there must be no discrimination between States or parts of States. And an excise is a duty upon goods manufactured or produced within a country. It is the product that is taxed-not the process of production; and if it is thought desirable to provide by law for an excise on goods already produced, there is no constitutional objection to this course.

[Vol. 1, p. 131]