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

Certiorari Denied

Petition for certiorari denied on January 21, 2025.

Docket No.24-332
Op. BelowN.Y.

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.

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