Oklahoma Tax Commission v. Jefferson Lines, Inc. (514 U.S. 175)

U.S. Supreme Court · decided April 3, 1995 · Supreme Court Database (Spaeth)

Citation
514 U.S. 175 · 115 S. Ct. 1331
Decided
April 3, 1995
Term
October Term 1994
Vote
7–2
Majority author
Justice Souter
Issue area
Economic Activity
Disposition
Reversed and remanded
Outcome
Petitioning party won
Ideological direction
Liberal

Opinion excerpt

Justice Souter delivered the opinion of the Court. This case raises the question whether Oklahoma’s sales tax on the full price of a ticket for bus travel from Oklahoma to another State is consistent with the Commerce Clause, U. S. Const., Art. I, § 8, cl. 3. We hold that it is. I Oklahoma taxes sales in the State of certain goods and services, including transportation for hire. Okla. Stat., Tit. 68, § 1354(1)(C) (Supp. 1988). The buyers of the taxable goods and services pay the taxes, which must be collected and remitted to the State by sellers. § 1361. Respondent Jefferson Lines, Inc., is a Minnesota corporation that provided bus services as a common carrier in Oklahoma from 1988 to 1990. Jefferson did not collect or remit the sales taxes for tickets it had sold in Oklahoma for bus travel from Oklahoma to other States, although it did collect and remit the taxes for all tickets it had sold in Oklahoma for travel that originated and terminated within that State. After Jefferson filed for bankruptcy protection on October 27, 1989, petitioner, Oklahoma Tax Commission, filed proof of claims in Bankruptcy Court for the uncollected taxes for tickets for interstate travel sold by Jefferson. Jefferson cited the Commerce Clause in objecting to the claims, and argued that the tax imposes an undue burden on interstate commerce by permitting Oklahoma to collect a percentage of the full…

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