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In the case of Oklahoma Tax Commission v. Jefferson Lines, Inc., 1994, the U.S Supreme Court ruled that a state could impose and collect sales tax on bus tickets for interstate travel sold within its borders. The court held that such taxation did not violate the Commerce Clause of the Constitution which prohibits states from interfering with interstate commerce. Jefferson Lines, a Minnesota-based company operating in several states including Oklahoma, had challenged an attempt by Oklahoma to collect unpaid sales taxes on ticket sales arguing it was unconstitutional as it interfered with interstate commerce. However, Justice Sandra Day O'Connor writing for majority stated that since the sale was completed in-state (Oklahoma), even though service was performed out-of-state or partly out-of-state (interstate), it didn't interfere with free flow of commerce across state lines thus upholding constitutionality of such taxation.
In the dissenting opinion for Oklahoma Tax Commission v. Jefferson Lines, Inc., Justice Scalia argued that the majority's decision to uphold Oklahoma's tax on bus tickets sold within its borders for interstate travel was inconsistent with previous rulings regarding state taxation of interstate commerce. He contended that this ruling effectively allowed a single state to impose a tax on an entire interstate transaction, which could lead to multiple states taxing the same transaction and thus burdening interstate commerce. Furthermore, he disagreed with the majority’s application of Complete Auto Transit test in determining whether or not such taxes were permissible under Commerce Clause jurisprudence. According to him, it failed to consider whether the taxed activity had substantial nexus with taxing State and if it was fairly apportioned so as not discriminate against out-of-state interests or cause double taxation.