Christopher H. Lunding, et Ux. v. New York Tax Appeals Tribunal et al. (522 U.S. 287)
U.S. Supreme Court · decided January 21, 1998 · Supreme Court Database (Spaeth)
- Citation
- 522 U.S. 287 · 118 S. Ct. 766
- Decided
- January 21, 1998
- Term
- October Term 1997
- Vote
- 6–3
- Majority author
- Justice O'Connor
- Issue area
- Economic Activity
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party lost
- Ideological direction
- Conservative
- Constitutional ruling
- State/territorial law held unconstitutional
Opinion excerpt
Justice O’Connor delivered the opinion of the Court. The Privileges and Immunities Clause, U. S. Const., Art. IV, §2, provides that “[t]he Citizens of each State shall be entitled to all Privileges and Immunities of Citizens in the several States.” In this case, we consider whether a provision of New York law that effectively denies only nonresident taxpayers an income tax deduction for alimony paid is consistent with that constitutional command. We conclude that because New York has not adequately justified the discriminatory treatment of nonresidents effected by N. Y. Tax Law § 681(b)(6), the challenged provision violates the Privileges and Immunities Clause. I A New York law requires nonresident individuals to pay tax on net income from New York real property or tangible personalty and net income from employment or business, trade, or professional operations in New York. See N. Y. Tax Law §§ 681(a), (b) (McKinney 1987). Under provisions enacted by the New York Legislature in 1987, the tax on such income is determined according to a method that takes into consideration the relationship between a nonresident taxpayer’s New York source income and the taxpayer’s total income, as reported to the Federal Government. § 601(e)(1). Computation of the income tax nonresidents owe New York involves several steps. First, nonresidents must compute their tax liability “as if” they…
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