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In the case of Heublein, Inc. v. South Carolina Tax Commission (1972), the U.S Supreme Court ruled in favor of Heublein, Inc., a Connecticut-based corporation that sold liquor to South Carolina wholesalers through an independent broker. The court held that South Carolina's imposition of a tax on Heublein was unconstitutional because it violated the Commerce Clause by discriminating against out-of-state businesses and burdening interstate commerce disproportionately compared to intrastate commerce. The state had imposed a license tax on all alcoholic beverages sold within its borders but exempted domestic manufacturers from paying this tax while requiring out-of-state companies like Heublein to pay it. This differential treatment between local and non-local businesses led the court to conclude that such taxation was discriminatory under the Commerce Clause. This ruling reaffirmed previous decisions where taxes were deemed unconstitutional if they placed undue burdens on interstate commerce or provided protectionist benefits for in-state businesses at expense of those located outside their jurisdiction.
In the dissenting opinion for Heublein, Inc. v. South Carolina Tax Commission, the justice argued that there was no substantial evidence to support a finding of discrimination against interstate commerce in this case. The justice believed that the tax imposed by South Carolina on liquor sales did not discriminate against out-of-state businesses because it applied equally to all sellers regardless of their location. Furthermore, they contended that any additional burden placed on interstate commerce as a result of this tax was incidental and permissible under established precedents. They also disagreed with the majority's interpretation of previous cases and suggested that these decisions should be read more narrowly than how they were interpreted by the majority in this case.