 Citing extensive Supreme Court precedent, Hughes asserted that the tax was not laid directly upon the government, its property, or its officers; that the state had not taxed an "instrumentality" of the government (since the company was an independent contractor); the tax was nondiscriminatory; and the tax did not apply directly to the contract issued by the federal government.Citing several Court precedents, Hughes argued for a close reading of the facts in order to determine the tax's validity