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Constitutional Law Keyed to Choper
Oklahoma Tax Commission v. Jefferson Lines, Inc.
Citation:
115 S. Ct. 1331 (1995)Facts
Jefferson Lines, a Minnesota corporation, provided bus services in Oklahoma from 1988 to 1990. While Jefferson collected and remitted Oklahoma sales taxes for tickets sold for intrastate travel (beginning and ending within Oklahoma), it did not collect or remit taxes for tickets sold in Oklahoma for interstate travel (beginning in Oklahoma but ending in another state). After Jefferson filed for bankruptcy in 1989, the Oklahoma Tax Commission filed claims for the uncollected taxes. Jefferson objected, arguing that the tax violated the Commerce Clause by permitting Oklahoma to collect tax on the full purchase price of interstate tickets, even though part of the value derived from travel through other states. The Commission contended that the sale of a bus ticket was a wholly local transaction justifying a sales tax on the ticket’s full value in the state where it was sold. The lower courts ruled in favor of Jefferson, finding the tax unconstitutional under Central Greyhound Lines, Inc. v. Mealey, which had struck down an unapportioned state tax on gross receipts from interstate bus travel.
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