United States Steel Corporation v. Multistate Tax Commission

PETITIONER: United States Steel Corporation
RESPONDENT: Multistate Tax Commission
LOCATION: New Jersey State Legislature

DOCKET NO.: 76-635
DECIDED BY: Burger Court (1975-1981)
LOWER COURT:

CITATION: 434 US 452 (1978)
ARGUED: Oct 11, 1977
DECIDED: Feb 21, 1978

ADVOCATES:
Erwin N. Griswold - Argued the cause for the appellants
William David Dexter - Argued the cause for the appellees

Facts of the case

In 1972, twenty one states were members of the Multistate Tax Compact, a body formed by states to assist them in formulating and administering tax law relating to multistate businesses. The Compact had not received congressional approval.

Question

Did the formation of this group violate the the Compact Clause of Article I?

Media for United States Steel Corporation v. Multistate Tax Commission

Audio Transcription for Oral Argument - October 11, 1977 in United States Steel Corporation v. Multistate Tax Commission

Audio Transcription for Opinion Announcement - February 21, 1978 in United States Steel Corporation v. Multistate Tax Commission

Lewis F. Powell, Jr.:

76-635 United States Steel Corporation and others against.

Multistate Tax Commission, brings us an appeal from Three-Judge District Court in the southern district of New York.19 states are members of an agreement called a Multistate Tax Compact.

This was entered into primarily to promote uniformity in state tax systems to facilitate the profit of termination of state and local tax liabilities.

And to minimize tax payer inconvenience and duplicate taxation.

The compact established in Multistate Tax Commission and endowed with various powers subject to the consent of the states.

These powers included the right to conduct tax audits in the member states.

Appellant corporations on behalf of themselves and other multistate taxpayers challenged the validity of the compact.

They argued that the compact is invalid under the Compact Clause of the Constitution, because it has not been approved by the Congress.

They also contained that it is unreasonably burdened interstate commerce and violates their rights under the Fourteenth Amendment.

For the reasons stated in an opinion filed with the clerk today, we reject appellant's constitutional challenges and affirm the judgment of the District Court that sustain the validity of the Multi-state Tax Compact.

Mr. Justice White has filed a dissenting opinion, in which Mr. Justice Blackmun joins.

Warren E. Burger:

Thank you Mr. Justice Powell.