Complete Auto Transit, Inc. v. Brady
United States Supreme Court
430 U.S. 274, 97 S.Ct. 1076, 51 L.Ed.2d 326 (1977)
- Written by Mary Pfotenhauer, JD
Facts
Mississippi assessed a tax on businesses, calculated as a percentage of gross income, for the privilege of doing business within the state. General Motors shipped vehicles from other states to Mississippi. Complete Auto Transit, Inc. (plaintiff) served as a contractor for General Motors, transporting vehicles within Mississippi to car dealers. Mississippi’s privilege tax was applied to Complete Auto’s gross income. Complete Auto paid the tax, but then filed a refund suit against Brady (defendant), the chairman of the Mississippi Tax Commission. Complete Auto argued that its activities were part of a broader interstate transaction and that states could not constitutionally impose a tax on interstate commerce for the privilege of doing business in the state. The Chancery Court upheld the tax as constitutional, and the Mississippi Supreme Court affirmed. The United States Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Blackmun, J.)
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