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ALLIED-SIGNAL, INC. v. DIRECTOR, DIV. OF TAXATION

No. 91-615.

504 U.S. 768 (1992)

ALLIED-SIGNAL, INC., as successor-in-interest TO BENDIX CORP. v. DIRECTOR, DIVISION OF TAXATION

Supreme Court of United States.

Reargued April 22, 1992.

Decided June 15, 1992.

Attorney(s) appearing for the Case

Walter Hellerstein reargued the cause for petitioner. With him on the briefs were Prentiss Willson, Jr., Harry R. Jacobs, Robyn H. Pekala, Andrew L. Frey, Kenneth S. Geller, Charles Rothfeld, and Bennett Boskey. Andrew L. Frey argued the cause for petitioner on the original argument. With him on the briefs were Messrs. Willson, Hellerstein, and Jacobs, Evan M. Tager, and Mr. Boskey.

Mary R. Hamill, Deputy Attorney General of New Jersey, reargued the cause for respondent. With her on the briefs were Robert J. Del Tufo, Attorney General, Joseph L. Yannotti, Assistant Attorney General, and Sarah T. Darrow, Deputy Attorney General.*

Kennedy, J., delivered the opinion of the Court, in which White, Stevens, Scalia, and Souter, JJ., joined. O'Connor, J., filed a dissenting opinion, in which Rehnquist, C. J., and Blackmun and Thomas, JJ., joined, p. 790.

Justice Kennedy, delivered the opinion of the Court.

Among the limitations the Constitution sets on the power of a single State to tax the multistate income of a nondomiciliary corporation are these: There must be "a `minimal connection' between the interstate activities and the taxing State," Mobil Oil Corp. v. Commissioner of Taxes of Vt., 445 U.S. 425, 436-437 (1980) (quoting...

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