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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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