U.S. AUTO PARTS NETWORK, INC. v. COMMISSIONER OF REVENUE

SJC-13283.

491 Mass. 122 (2022)

U.S. AUTO PARTS NETWORK, INC. v. COMMISSIONER OF REVENUE.

Supreme Judicial Court of Massachusetts, Suffolk.

December 22, 2022.


Attorney(s) appearing for the Case

Julie E. Green , Assistant Attorney General, for Commissioner of Revenue.

George S. Isaacson ( Martin I. Eisenstein & David Swetnam-Burland , of Maine, & Jamie E. Szal also present) for the taxpayer.

The following submitted briefs for amici curiae:

Ben Robbins & Daniel B. Winslow for New England Legal Foundation.

Tyler L. Martinez , of the District of Columbia, & Karen A. Pickett for National Taxpayers Union Foundation.

Frank J. Bailey , Selena Fitanides , John C. La Liberte , Matthew Schaefer , & Richard L. Jones for PioneerLegal, LLC.

Present: Budd, C.J., Gaziano, Lowy, Cypher, Kafker, Wendlandt, & Georges, JJ.


For more than half a century, the United States Supreme Court adhered to a "bright-line rule" as it pertained to the constitutional limits of a State's authority to impose an obligation on a nondomiciliary seller to collect and remit a sales or use tax when a consumer purchases its goods or services for use or consumption in the State...

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