 The Court had already held, in "Thomson v. Pacific Railroad", 76 U.S. 579 (1869), that there was a clear distinction between taxing the government or one of its instrumentalities and taxing a contract employed by the government.Hughes distinguished "Pollock v. Farmers' Loan & Trust Co.", 157 U.S. 429 (1895); "Gillespie v. Oklahoma", 257 U.S. 501 (1922); and "Metcalf & Eddy v. Mitchell", 269 U.S. 514 (1926), from the current case, in part because of the nature of the revenue stream being taxed (bond income, for example, rather than a payment under a government contract) and because of the local (rather than interstate) nature of the work done.The heart of the taxation argument, Hughes finally concluded, rested on the contention that the business would automatically pass the cost of the tax on to the federal government, thus hindering the government in the provision of goods and services.