| 25-382 |
Alicia Stroble v. Oklahoma Tax Commission |
Oklahoma |
2025-10-01 |
Pending |
Amici (4)Relisted (4) |
indian-country mcgirt-precedent reservation-rights state-taxation tax-jurisdiction tribal-sovereignty |
Whether Oklahoma may tax the income of a Muscogee (Creek) Nation citizen who lives and works within the Muscogee (Creek) Reservation that McGirt v. Ok… |
| 24-332 |
International Business Machines Corporation & Combined Affiliates v. New York Tax Appeals Tribunal, et al. |
New York |
2024-09-24 |
Denied |
Amici (1) |
commerce-clause double-taxation foreign-commerce interstate-commerce state-taxation tax-nexus |
May a state impose a 'heads I win, tails you lose' regime that taxes either side of an interstate or foreign transaction, depending on which side has … |
| 24-5334 |
Russell G. Conlon v. Oklahoma Department of Human Services, Child Support Services, et al. |
Oklahoma |
2024-08-15 |
Denied |
Response WaivedIFP |
child-support constitutional-challenges criminal-procedure due-process judicial-recusal state-taxation |
Whether a court can convict an American citizen without trial after pleading not guilty, whether a judge can rule on matters during a recusal action, … |
| 24A52 |
The Walt Disney Company v. New York Tax Appeals Tribunal, et al. |
New York |
2024-07-16 |
Presumed Complete |
|
dormant-commerce-clause facial-discrimination interstate-commerce royalty-income state-taxation strict-scrutiny |
Whether a state tax law that conditions a royalty income exclusion on the geographic location of the royalty payor constitutes impermissible discrimin… |
| 23-1202 |
Ellingson Drainage, Inc. v. South Dakota Department of Revenue |
South Dakota |
2024-05-09 |
Denied |
Amici (1)Response Waived |
commerce-clause constitutional-challenge external-consistency fair-apportionment movable-equipment sales-tax state-tax-credits state-taxation use-tax |
Whether South Dakota's imposition of an unapportioned use tax on the fair market value of Petitioner's movable construction equipment violates the fai… |
| 23-402 |
Oklahoma, et al. v. United States, et al. |
Sixth Circuit |
2023-10-17 |
Rehearing |
Amici (5)Relisted (6) |
administrative-law anti-commandeering federal-rulemaking federal-trade-commission horseracing-industry non-delegation-doctrine private-non-delegation regulatory-power state-funding state-taxation |
Does the Horseracing Integrity and Safety Act of 2020 violate the private non-delegation doctrine and the anti-commandeering doctrine? |
| 23-171 |
Chris Quinn, et al. v. Washington, et al. |
Washington |
2023-08-23 |
Denied |
Amici (2)Response RequestedResponse WaivedRelisted (4) |
commerce-clause constitutional-limits dormant-commerce-clause due-process excise-tax extraterritorial-taxation federalism interstate-commerce property-rights state-taxation |
Whether the Constitution permits a state to tax out-of-state transactions involving only out-of-state property |
| 22-890 |
Quad Graphics, Inc. v. North Carolina Department of Revenue |
North Carolina |
2023-03-16 |
Denied |
Amici (4) |
commerce-clause constitutional-interpretation due-process interstate-sales judicial-precedent out-of-state-sales precedent state-courts state-taxation supreme-court-precedent |
Whether the North Carolina Supreme Court was correct that state courts and taxing authorities no longer must follow Dilworth because this Court has im… |
| 21-1488 |
Ooma, Inc. v. Oregon Department of Revenue |
Oregon |
2022-05-26 |
Denied |
Response Waived |
commerce-clause due-process e911-tax state-taxation substantial-nexus virtual-contacts wayfair wayfair-precedent |
Does the Commerce Clause prevent the imposition of Oregon's E911 tax where the lower court dismissed the 'virtual contacts' inquiry as irrelevant to t… |
| 21-7775 |
In Re Crystal Maye |
|
2022-05-04 |
Denied |
IFP |
agency-law civil-procedure civil-rights constitutional-protections due-process jurisdictional-challenge state-taxation tax-jurisdiction taxation trustee-residency trusts |
whether agency proceedually followed notice requirement to service trustee, on Trust, or beneficaries or , whether Court over reach authority to tax t… |
| 21-1298 |
Leonard Albrecht, et al. v. Riverside County, California, et al. |
California |
2022-03-28 |
Denied |
Amici (1)Response Waived |
federal-preemption indian-lands indian-reorganization-act leasehold-interest reservation-rights state-taxation tax-preemption tribal-sovereignty |
Whether federal regulations governing the leasing of Indian lands preempt state and local governments from taxing the leasehold interest conveyed by t… |
| 21-1066 |
Washington Bankers Association, et al. v. Washington, et al. |
Washington |
2022-02-01 |
Denied |
Amici (6)Response RequestedResponse WaivedRelisted (2) |
circuit-split corporate-taxation discriminatory-proxy discriminatory-taxation dormant-commerce-clause interstate-commerce out-of-state-entities precedents proxy-discrimination state-taxation |
Does a law that is triggered by a proxy for participating in interstate commerce and that burdens out-of-state entities almost exclusively violate the… |
| 21-641 |
Ferrellgas Partners, LP v. Director, Division of Taxation |
New Jersey |
2021-11-02 |
Denied |
Amici (4)Response RequestedResponse WaivedRelisted (2) |
commerce-clause general-fund internal-consistency interstate-commerce partnership-levy regulatory-fee state-taxation |
Whether a levy that raises revenue for a State's general fund, and that is not restricted to the in-state activities of the levy-payor, may be charact… |
| 20-1159 |
Vermont National Telephone Company v. Vermont Department of Taxes |
Vermont |
2021-02-23 |
Denied |
Response RequestedResponse WaivedRelisted (2) |
constitutional-interpretation due-process federal-communications-commission federal-license nonbusiness-income situs situs-principle state-taxation whitney-v-graves |
Whether the Vermont Supreme Court erred in holding that a federal license, that can be used only in one state, lacks a situs in that state under Whitn… |
| 20-947 |
Idaho State Tax Commission v. Noell Industries, Inc. |
Idaho |
2021-01-14 |
Denied |
Amici (1)Response Waived |
business-enterprise corporate-taxation due-process judicial-split pass-through-entities pass-through-entity state-court-split state-tax state-taxation unitary-business |
Does this Court's ruling in Mobil apply to pass-through entities? |
| 20-468 |
Xpedite Systems, Inc. v. John J. Ficara, Acting Director, New Jersey Division of Taxation |
New Jersey |
2020-10-09 |
Denied |
Amici (1)Response Waived |
apportionment commerce-clause deference due-process due-process-clause interstate-commerce revenue-reapportionment state-taxation tax-apportionment |
Whether granting unfettered deference to a State tax commissioner's decision to reapportion the revenues of an interstate business violates the Due Pr… |
| 19-1298 |
Rogers County Board of Tax Roll Corrections, et al. v. Video Gaming Technologies, Inc. |
Oklahoma |
2020-05-19 |
Denied |
Amici (1)Relisted (3) |
ad-valorem-tax bracker-balancing-test federal-preemption government-interests indian-gaming-regulatory-act non-indian-entity non-indian-property state-taxation tribal-sovereignty |
Whether a generally applicable state ad valorem tax, as assessed against personal property owned by a non-Indian, out-of-state corporate entity and le… |
| 19-1056 |
Kristi Noem, Governor of South Dakota, et al. v. Flandreau Santee Sioux Tribe |
Eighth Circuit |
2020-02-26 |
Denied |
|
economic-impacts fiscal-demands preemption state-interests state-taxation bracker-test economic-impacts federal-regulation indian-gaming preemption state-interests state-taxation tribal-sovereignty |
Does the Bracker test currently serve as a consistent and predictable rule of law in light of the exponential expansion of Indian gaming since 1988 an… |
| 19-949 |
Wisconsin Department of Revenue, et al. v. Union Pacific Railroad Company |
Seventh Circuit |
2020-01-29 |
Denied |
|
4-r-act commercial-entities discrimination-claim intangible-property property-tax property-tax-exemption railroad-taxation state-taxation tax-exemption |
Does a State violate subsection (b)(4) by exempting intangible-personal-property of non-railroads from its personal-property-tax, but not exempting su… |
| 19-921 |
John M. Paz v. Director, New Jersey Division of Taxation |
New Jersey |
2020-01-24 |
Denied |
Amici (1)Response Waived |
allocation apportionment commerce-clause corporate-income-tax due-process multistate-business state-taxation unitary-business unitary-business-principle |
Whether a state can allocate the entire gain from the sale of a unitary business's assets to itself for taxation purposes |
| 19-755 |
Robert C. Steiner, et ux. v. Utah State Tax Commission |
Utah |
2019-12-12 |
Denied |
Amici (3)Response Waived |
dormant-commerce-clause double-taxation equal-protection foreign-commerce interstate-taxation state-residency state-tax-credits state-taxation tax-credit tax-credits |
Whether Utah's tax code discriminates against foreign commerce in violation of the dormant Commerce Clause |
| 19-136 |
Saban Rent-A-Car LLC, et al. v. Arizona Department of Revenue, et al. |
Arizona |
2019-07-29 |
Denied |
Amici (1)Response Waived |
arizona-supreme-court maricopa-county nonresident-taxation rental-car-industry tax-discrimination car-rental-tax commerce-regulation discriminatory-design discriminatory-purpose dormant-commerce-clause interstate-commerce nonresident-burden nonresident-discrimination state-taxation tax-discrimination tax-incidence |
Whether a car-rental tax designed to foist a disproportionate share of the tax's burden onto nonresidents is nonetheless immune from dormant Commerce … |
| 19-119 |
Staples, Inc., et al. v. Comptroller of the Treasury of Maryland |
Maryland |
2019-07-24 |
Denied |
Response RequestedResponse WaivedRelisted (2) |
apportionment commerce-clause constitutional-taxation due-process franchise-fees income-apportionment income-tax interstate-commerce royalty royalty-fees royalty-income state-courts state-taxation |
When an out-of-State business receives royalty fees, franchise fees, or similar payments from in-State businesses, may a State imposing income taxes c… |
| 18-1570 |
Samuel Edelman, et ux. v. New York State Department of Taxation and Finance, et al. |
New York |
2019-06-24 |
Denied |
Amici (5) |
double-taxation due-process residency state-taxation tax-credits ' domicile' comptroller-of-treasury-of-maryland-v-wynne constitutional-challenge domicile dormant-commerce-clause intangible-income interstate-taxation state-taxation tax-credits wynne-precedent |
The issue being raised is whether a state tax scheme that taxes the intangible income of individuals who are domiciled in the State and certain indivi… |
| 18-1569 |
Richard Chamberlain, et ux. v. New York State Department of Taxation and Finance, et al. |
New York |
2019-06-24 |
Denied |
|
comptroller-of-treasury-of-maryland-v-wynne constitutional-challenge domicile dormant-commerce-clause double-taxation intangible-income interstate-taxation state-taxation tax-credits tax-jurisdiction tax-residency wynne-precedent |
Whether a state tax scheme that taxes the intangible income of individuals who are domiciled in the State and certain individuals not domiciled in the… |
| 18-1485 |
Michael Kansler, et ux. v. Mississippi Department of Revenue |
Mississippi |
2019-05-29 |
Denied |
Response Waived |
commerce-clause double-taxation due-process income-tax internal-consistency internal-consistency-test interstate-commerce residency state-tax-law state-taxation statute-of-limitations tax-statute-of-limitations |
Whether Mississippi's income tax refund statute of limitation is immune from Commerce Clause scrutiny under Complete Auto Transit and the internal con… |
| 18-807 |
Randolph S. Baskins, et ux. v. Oklahoma Tax Commission |
Oklahoma |
2018-12-21 |
Denied |
Response RequestedResponse WaivedRelisted (2) |
capital-gains commerce-clause constitutional-law dormant-commerce-clause due-process equal-protection state-taxation tax-deduction |
Does the Oklahoma Capital Gains Deduction tax scheme as set forth in 68 O.S. 2011, § 2358(F) as applied to Randolph S. Baskins and Beverly J. Baskins … |
| 18-664 |
Cynthia Bauerly, Commissioner, Minnesota Department of Revenue v. William Fielding, Trustee of the Reid and Ann MacDonald Irrevocable GST Trust for Maria V. MacDonald, et al. |
Minnesota |
2018-11-21 |
Denied |
Relisted (2) |
conflict-of-laws constitutional-law due-process family-business income-tax income-taxation resident-trust resident-trusts state-taxation trustee-location |
Does the Due Process Clause prohibit states from imposing incomes taxes on statutory 'resident trusts' that have significant additional contacts with … |
| 18-612 |
CSX Transportation, Inc. v. Alabama Department of Revenue, et al. |
Eleventh Circuit |
2018-11-09 |
Denied |
CVSGAmici (1)Relisted (2) |
commerce-clause csx-transportation discrimination discriminatory-taxation dormant-commerce-clause equal-protection interstate-commerce motor-carrier motor-carrier-tax preemption railroad-fuel state-taxation supreme-court-precedent tax-discrimination tax-jurisprudence |
Whether Alabama's imposition of a motor fuels tax on interstate motor carriers justifies its facially discriminatory sales and use tax on railroad die… |
| 18-457 |
North Carolina Department of Revenue v. The Kimberley Rice Kaestner 1992 Family Trust |
North Carolina |
2018-10-11 |
Judgment Issued |
Amici (14)Response RequestedResponse WaivedRelisted (3) |
beneficiary-residency constitutional-challenge due-process federalism pennoyer-v-neff state-courts state-revenue state-tax-revenue state-taxation trust trust-income trust-taxation |
Does the Due Process Clause prohibit states from taxing trusts based on trust beneficiaries' in-state residency? |
| 18-447 |
Alabama Department of Revenue, et al. v. CSX Transportation, Inc. |
Eleventh Circuit |
2018-10-10 |
Denied |
CVSGAmici (1)Relisted (2) |
commerce-clause discrimination dormant-commerce-clause equal-protection fuel-exemption interstate-commerce preemption state-taxation statutory-interpretation tax-discrimination tax-exemption transportation-carriers |
Under 49 U.S.C. § 11501(b)(4), when can a State justifiably maintain a sales-and-use tax exemption for fuel used by vessels to transport goods interst… |
| 18-297 |
Eric White, et al. v. Barbara D. Underwood, Attorney General of New York, et al. |
New York |
2018-09-07 |
Denied |
Amici (1)Response Waived |
canons-of-construction federal-indian-law indian-law indian-rights indian-treaty-rights native-american-rights new-york-indians seneca-nation sovereign-immunity state-taxation statutory-interpretation supreme-court-precedent tax-assessment treaty-interpretation tribal-sovereignty |
Does New York's assessment and collection of taxes within the Seneca Nation of Indians violate the treaty rights of the Seneca Nation? |
| 18-205 |
Northern California Water Association, et al. v. California State Water Resources Control Board, et al. |
California |
2018-08-16 |
Denied |
Response Waived |
central-valley-project federal-property intergovernmental-immunity preemption property-rights sovereign-immunity state-taxation state-water-board supremacy-clause tax-assessment taxation water-contractors water-contracts water-rights |
Is a California statute imposing a direct tax on the United States' property interest in water constitutional if it is applied in a manner that passes… |