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FRANCHISE TAX BOARD OF CALIFORNIA v. USPS

No. 83-372.

467 U.S. 512 (1984)

FRANCHISE TAX BOARD OF CALIFORNIA v. UNITED STATES POSTAL SERVICE

Supreme Court of United States.

Decided June 11, 1984

Attorney(s) appearing for the Case

Patti S. Kitching, Deputy Attorney General of California, argued the cause for appellant. With her on the briefs were John K. Van De Kamp, Attorney General, and Edmond B. Mamer, Deputy Attorney General.

David A. Strauss argued the cause for appellee. With him on the brief were Solicitor General Lee, Acting Assistant Attorney General Willard, Deputy Solicitor General Geller, and Joan M. Bernott.*

JUSTICE STEVENS delivered the opinion of the Court.

Appellant, the Franchise Tax Board of California, determined that four employees of appellee United States Postal Service were delinquent in the payment of their state income taxes. The Board served process on the Postal Service directing it to withhold the amounts of the delinquencies from the employees' wages, pursuant to § 18817 of the California Revenue and Taxation Code, which authorizes the Board to

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