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General Trading Co. v. State Tax Commission of Iowa

322 U.S. 335, 64 S. Ct. 1028 (1944)

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General Trading Co. v. State Tax Commission of Iowa

United States Supreme Court

322 U.S. 335, 64 S. Ct. 1028 (1944)

Facts

General Trading Co. (defendant) was a Minnesota corporation that did business in Iowa. General Trading sent salesmen to Iowa to solicit orders from Iowa customers. General Trading accepted the orders and shipped the goods from Minnesota. Iowa imposed a use tax on tangible personal property purchased outside the state for use in the state. Iowa’s use-tax law provided an offsetting credit to a customer if the customer had already paid a use or sales tax on the personal property in a different state. Iowa applied its use tax to General Trading’s sales made to Iowa customers. The State Tax Commission of Iowa (plaintiff) filed a lawsuit in state court to sustain its application of the use tax on General Trading. The lower court upheld the application of the use tax, and the Iowa Supreme Court affirmed the lower court. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Frankfurter, J.)

Concurrence (Rutledge, J.)

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