United States v. Ptasynski, 462 U.S. 74 (1983)

APPEAL FROM DISTRICT COURT OF WYOMING

Syllabus

The Crude Oil Windfall Profit Tax Act of 1980 exempts from the tax imposed by the Act domestic crude oil defined as oil produced from wells located north of the Arctic Circle or on the northerly side of the divide of the Alaska-Aleutian Range and at least 75 miles from the nearest point on the Trans-Alaska Pipeline system.

Held. This exemption does not violate the Uniformity Clause’s requirement that taxes be "uniform throughout the United States." Pp. 80-86.

(a) The Uniformity Clause does not require Congress to devise a tax that falls equally or proportionately on each State, nor does the Clause prevent Congress from defining the subject of a tax by drawing distinctions between similar classes. Pp. 80-82.

(b) Identifying "exempt Alaskan oil" in terms of its geographic boundaries does not render the exemption invalid. Neither the language of the Uniformity Clause nor this Court’s decisions prohibit all geographically defined classifications. That Clause gives Congress wide latitude in deciding what to tax, and does not prohibit it from considering geographically isolated problems. Here, Congress cannot be faulted for determining, based on neutral factors, that "exempt Alaskan oil" required separate favorable treatment. Such determination reflects Congress’ considered judgment that unique climatic and geographic conditions required that oil produced from the defined region be exempted from the windfall profit tax, which was devised to tax "windfalls" that some oil producers would receive as the result of the deregulation of domestic oil prices that was part of the Government’s program to encourage the exploration for and production of oil. Pp. 84-86.

550 F.Supp. 549, reversed.

POWELL, J., delivered the opinion for a unanimous Court.