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U.S. Supreme Court Denies Review of Florida v. California

Andrew D. Appleby
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Perry Cooper (Bloomberg Law): Supreme Court Stays Out of Florida’s Tax Dispute With California

The US Supreme Court declined to take the unusual step of hearing a tax dispute among two states—in this case, Florida alleging a California rule deprives it of tax and investment revenue.

Florida filed a motion for leave to file a bill of complaint asking the high court to block California’s requirement that businesses exclude proceeds from “substantial and occasional” sales from their state tax returns, which Florida says distorts the taxable income California can lay claim to regarding multi-state businesses.

…

Justice Clarence Thomas, joined by Justice Samuel A. Alito Jr., dissented, arguing that federal law doesn’t give the court discretion to decline to decide cases within its original jurisdiction.

The case is Florida v. California , U.S., No. 22o163, review denied 6/1/26

About the Author

Andrew D. Appleby Avatar
Andrew D. Appleby
Andrew Appleby is an Associate Professor of Law at the University of Tennessee Winston College of Law. He has particular expertise in state and local taxation, taxation of the digital economy, sports taxation, and applied tax policy. Prior to joining academia, he practiced multistate tax law at leading law firms for a decade, and he now co-authors the State Taxation treatise with Prof. Walter Hellerstein.
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