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American Oil Co. v. Neill, 380 U.S. 451 (1965)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
American Oil Co. v. Neill, 380 U.S. 451 (1965)
American Oil Co. v. Neill No. 19 Argued January 25-26, 1965 Decided April 26, 1965 380 U.S. 451
APPEAL FROM THE SUPREME COURT OF IDAHO
Syllabus
From its Seattle Regional Office, the Government Services Administration (GSA) invited bids to supply motor fuel for use by government agencies in Idaho and other States. Utah Oil Refining Company (Utah Oil) made bids from its Salt Lake City offices, including two bids for supplying gasoline to the Atomic Energy Commission (AEC), each bid being made alternatively for delivery f.o.b. Salt Lake City or the AEC site in Idaho. GSA at Seattle, awarded Utah Oil the contract for delivery of the gasoline at Utah Oil’s Salt Lake City bulk plant, where title passed. AEC arranged for transportation of the gasoline to its Idaho site by common carriers. Utah Oil was licensed as a "dealer" in Idaho, but its activities there were unrelated to the GSA contract. Appellee Idaho State Tax Collector imposed an excise tax on the transaction under a statute taxing the "dealer" who first "receives" motor fuel in the State, the statute making a licensed dealer the constructive recipient of motor fuel unloaded in Idaho which it sold out of state for in-state use to a purchaser without a license. The tax was paid under protest by Utah Oil which appellant, its successor in interest, now seeks to have refunded. The trial court granted appellant summary judgment, holding the tax invalid, since applied to a sale outside Idaho. The Idaho Supreme Court reversed.
Held:
1. The operating incidence of the tax fell on the dealer, who was not required to pass it on to or collect it from the consumer. Pp. 455-457.
2. A State’s imposition of an excise tax with respect to an out of state transaction upon a dealer entirely dissociated from any in-state activities violates the Due Process Clause. Pp. 457-459.
(a) The vendor’s knowledge that the commodity sold was for use in the State would not of itself make the tax on the out of state sale permissible. P. 457.
(b) Since every phase of the transaction here occurred outside the taxing State, neither the fact that the dealer was licensed in the State nor that it performed activities in the State suffices to uphold the tax. Pp. 458-459.
86 Idaho 7, 383 P. 2d 350, reversed and remanded.
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Chicago: U.S. Supreme Court, "Syllabus," American Oil Co. v. Neill, 380 U.S. 451 (1965) in 380 U.S. 451 380 U.S. 452. Original Sources, accessed November 24, 2024, http://originalsources.com/Document.aspx?DocID=VLNAWJ2ZTGMBUCK.
MLA: U.S. Supreme Court. "Syllabus." American Oil Co. v. Neill, 380 U.S. 451 (1965), in 380 U.S. 451, page 380 U.S. 452. Original Sources. 24 Nov. 2024. http://originalsources.com/Document.aspx?DocID=VLNAWJ2ZTGMBUCK.
Harvard: U.S. Supreme Court, 'Syllabus' in American Oil Co. v. Neill, 380 U.S. 451 (1965). cited in 1965, 380 U.S. 451, pp.380 U.S. 452. Original Sources, retrieved 24 November 2024, from http://originalsources.com/Document.aspx?DocID=VLNAWJ2ZTGMBUCK.
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