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IBM Corp. & Combined Affiliates v. New York Tax Appeals Tribunal

Petition for certiorari denied on January 21, 2025

Docket No. Op. Below Argument Opinion Vote Author Term
24-332 N.Y. N/A N/A N/A N/A OT 2024

Issue: Whether a state may impose a "heads I win, tails you lose" regime that taxes either side of an interstate or foreign transaction, depending on which side has a nexus to the state, even though such a regime would inherently disadvantage interstate and foreign commerce if it were replicated by every jurisdiction.

SCOTUSblog Coverage

DateProceedings and Orders (key to color coding)
07/10/2024Application (24A36) to extend the time to file a petition for a writ of certiorari from July 22, 2024 to September 20, 2024, submitted to Justice Sotomayor.
07/16/2024Application (24A36) granted by Justice Sotomayor extending the time to file until September 20, 2024.
09/19/2024Petition for a writ of certiorari filed. (Response due October 24, 2024)
10/02/2024Motion to extend the time to file a response from October 24, 2024 to December 16, 2024, submitted to The Clerk.
10/03/2024Motion to extend the time to file a response is granted and the time is extended to and including December 16, 2024.
10/23/2024Brief amicus curiae of Council On State Taxation filed.
12/16/2024Brief of respondent New York State Commissioner of Taxation and Finance in opposition filed.
12/30/2024Reply of petitioner International Business Machines Corporation and Combined Affiliates filed. (Distributed)
12/31/2024DISTRIBUTED for Conference of 1/17/2025.
01/21/2025Petition DENIED.