Nobody at losthorizons can answer a simple question

[Famspear]

Nothing in here contributes to explaining how intergovernmental tax immunity applies in instances where there is a burden on the agency itself, both monetary and administrative.

You do not even understand burden vs no burden and YOU want to explain the law?

Try again, if you wish. I care not, and obviously you do neither. It would seem you come here to troll because your woman won't let you do this to her at home.

No, I don't need to "try again." Your discussion, such as it is, with the concept of "intergovernmental tax immunity" is with someone else in this thread, not with me. I haven't even mentioned the subject. I know there are several people posting in this thread, kiddo, but you need to do a better job of keeping track of what it is you're discussing with whom.

No, I don't "come here" to "troll." For all material intents and purposes, I live here, bozo, and I've been living here, so to speak, since May of 2007. You're the newcomer, and you're the one being accused of being a troll (not by me, but by others here).

Mental NOTE::
1. So far I have learned that there are two different verbs 'to regulate,' one from Black's and one which may or may not be from Black's. Thanks Famspear.

Again, you keep referencing me regarding your apparent confusion about the verb "to regulate." And you keep referring to Black's Law Dictionary. You and I have not had any such discussion.

You were (and still are) confused about the constitutional law concepts of "taxation" and "regulation," and I explained some of the basics to you.

I know what I'm talking about. You do not know what you're talking about.

Here, chew on this:

If you work for a federal or state government agency of ANY KIND WHATSOEVER, your gross earnings from the agency are includible in income under section 61 of the Internal Revenue Code of 1986 and, under the 1986 Code, there is no exclusion with respect to those earnings based on the concept of "intergovernmental tax immunity".

Now, if you feel up to it, go look for a federal court ruling that says I'm wrong. (That would be a fool's errand; there is no such ruling.)

[stija]

Famspear, so.....first you are not discussing it with me and now you are? I am confused, are we discussing it or not? And if aren't then are you not trolling by definition and clogging the post with irrelevant personal beliefs?

If you work for a federal or state government agency of ANY KIND WHATSOEVER, your gross earnings from the agency are includible in income under section 61 of the Internal Revenue Code of 1986 and, under the 1986 Code, there is no exclusion with respect to those earnings based on the concept of "intergovernmental tax immunity".

This is legal evidence from Title 26 section ......? Exactly.

You were (and still are) confused about the constitutional law concepts of "taxation" and "regulation," and I explained some of the basics to you.

From: http://constitution.findlaw.com/article ... ion26.html

PURPOSES OF TAXATION

Regulation by Taxation

The discretion of Congress in selecting the objectives of taxation has also been held at times to be subject to limitations implied from the nature of the Federal System. Apart from matters that Congress is authorized to regulate, the national taxing power, it has been said, ''reaches only existing subjects.'' 513 Congress may tax any activity actually carried on, such as the business of accepting wagers, 514 regardless of whether it is permitted or prohibited by the laws of the United States 515 or by those of a State. 516 But so- called federal ''licenses,'' so far as they relate to trade within state limits, merely express, ''the purpose of the government not to interfere . . . with the trade nominally licensed, if the required taxes are paid.'' Whether the ''licensed'' trade shall be permitted at all is a question for decision by the State. 517 This, nevertheless, does not signify that Congress may not often regulate to some extent a business within a State in order to tax it more effectively. Under the necessary- and-proper clause, Congress may do this very thing. Not only has the Court sustained regulations concerning the packaging of taxed articles such as tobacco 518 and oleomargarine, 519 ostensibly designed to prevent fraud in the collection of the tax, it has also upheld measures taxing drugs 520 and fire arms, 521 which prescribed rigorous restrictions under which such articles could be sold or transferred, and imposed heavy penalties upon persons dealing with them in any other way. These regulations were sustained as conducive to the efficient collection of the tax though they clearly transcended in some respects this ground of justification. 522

To tax is to indirectly (i would argue DIRECTLY but ok) regulate. I guess it depends on your two definition of the word regulate. I would say that IRC not only regulates but it is a social engineering tool that Congress uses to stimulate the economy and regulate individual behavior - keep money flowing around and you pay no tax, but if you save or cash out, a penalty/tax imposed. You do not see it? When Barack says that he is going to lower taxes on middle class Americans to stimulate the economy, that is just taxation and not stimulation of the economy??

Go back to the troll hole you came from and stay there. You are arrogant but ignorant - the worst possible combination. I can only imagine what you would have called me if i quoted propaganda and gibberish instead of legal evidence.

[Pottapaug1938]

You have a hard time getting ANYTHING straight, Pal. I did NOT say that the 16th Amendment did nothing. What I DID say that was that the Amendment grated no new power to tax because Congress already had that power. The Amendment simply removed restrictions on that power (apportionment and source). I've already told you that further enlightenment can be had on old threads within this topic; but you should start with the case of Brushaber v. Union Pacific Railroad, 240 U.S. 1 (1916).

What restrictions? Excise taxes were at some point restricted or required to be apportionment?

Your words:

You are right about the bit about no new powers of taxation being added -- but that's old news to the regulars here. What the 16th Amendment did was remove the requirement for apportionment, and made the source of the income irrelevant, so that now, whenever you receive income, it doesn't matter how, where or from whom or what you got it, it is still sublect to the federal income tax.

In order to remove a requirement of apportionment, there needs to be a requirement first. You inferred that there was one and it was removed. It's my ESL English bro, sorry.

Pal, that is not what the court said. The court said that the XVI removed any confusion that the income tax is in the class of excise taxes which are NOT SUBJECT to apportionment, and from this point on should NEVER be confused with a direct tax which is subject to apportionment.

Therefore, XVI did nothing whatsoever, as ruled by many courts, including the one you quoted. It merely may have tried to avoid the Pollock argument again. But Pollock's property was NOT taxable in the first place, which is why it was held unconstitutional - what can't be reached directly cannot be reached indirectly by taxing the profits of rents from real estate coming from an untaxable source. It wasn't a question of income taxes specifically, but capital gained from private property of Loan and Trust Co. In fact, the court would have rendered void only sections 23-37 (or something) but then held that the taxing burden would then rest wholly on income taxation of professions and vocations which could not have been the intent of the code.

Stop selling nonsense and confusing yourself. But i am willing to agree with you because it is ultimately irrelevant.

You completely mischaracterize Pollock --- but why should that surprise me? The 16th Amendment was crafted to get around the very barrier which provented the imposition of the income tax in the Pollock case. As for "what restrictions" -- you answered your own question; and on top of that I've already answered it.

[Famspear]

Therefore, XVI did nothing whatsoever, as ruled by many courts, including the one you quoted. It merely may have tried to avoid the Pollock argument again. But Pollock's property was NOT taxable in the first place, which is why it was held unconstitutional...

Wrong. That's not correct, and that's not what the Court ruled in the Pollock case.

The Court ruled that a tax on INCOME from property (in the form of rents, dividends or interest) was required to be apportioned and that, since the 1894 Act did not provide for an apportionment of such taxes, the Act was unconstitutional. In effect, although all federal income taxes had theretofore been considered excises (indirect taxes) the Court treated a particular kind of income tax as a direct tax -- meaning that this kind of tax had to be apportioned.

The Court never ruled that Pollock's property "was not taxable in the first place."

The Sixteenth Amendment effectively overruled the Pollock decision. Because of the Sixteenth Amendment, with respect to the APPORTIONMENT REQUIREMENT it makes no difference whether a given court considers a given federal income tax to be a direct tax or an excise. If it's an income tax, it's not required to be apportioned. Period.

[stija]

The Court ruled that a tax on INCOME from property (in the form of rents, dividends or interest) was required to be apportioned and that, since the 1894 Act did not provide for an apportionment of such taxes, the Act was unconstitutional. In effect, although all federal income taxes had theretofore been considered excises (indirect taxes) the Court treated a particular kind of income tax as a direct tax -- meaning that this kind of tax had to be apportioned.

Bravo. Why did they rule it needed to be apportioned? Maybe, just maybe, because real property is only subject to direct taxation and the requirement of apportionment?

The tax laws tried to tax the proceeds from a source that was only taxable under direct taxation, thus the court used substance instead of form to rule that Congress tried to tax indirectly without apportionment something which required apportionment and was subject to direct taxation ONLY.

Substance/character was real property. Real property subject to direct taxation only.
Form used to tax property was income taxes. Income taxes are excises not subject to apportionment.
Principles of direct vs indirect in regard to substance, form is subject to rule of apportionment or uniformity.
Therefore, to tax something which can only be taxed by direct taxation using indirect form is unconstitutional.

His property was not taxable under the act. I did not mean NOT taxable at all.

You guys are really good at swallowing your own BS.

[Cpt Banjo]

To tax is to indirectly (i would argue DIRECTLY but ok) regulate. I guess it depends on your two definition of the word regulate. I would say that IRC not only regulates but it is a social engineering tool that Congress uses to stimulate the economy and regulate individual behavior - keep money flowing around and you pay no tax, but if you save or cash out, a penalty/tax imposed.

The fact that a tax has collateral regulatory effects is irrelevant.

It is beyond serious question that a tax does not cease to be valid merely because it regulates, discourages, or even definitely deters the activities taxed. Sonzinsky v. United States, 300 U.S. 506, 513 -514 (1937). The principle applies even though the revenue obtained is obviously negligible, Sonzinsky v. United States, supra, or the revenue purpose of the tax may be secondary, Hampton & Co. v. United States, 276 U.S. 394 (1928). Nor does a tax statute necessarily fall because it touches on activities which Congress might not otherwise regulate. As was pointed out in Magnano Co. v. Hamilton, 292 U.S. 40, 47 (1934):

"From the beginning of our government, the courts have sustained taxes although imposed with the collateral intent of effecting ulterior ends which, considered apart, were beyond the constitutional power of the lawmakers to realize by legislation directly addressed to their accomplishment." United States v. Sanchez, 304 U.S. 42, 44-45 (1950)

[Famspear]

The Court ruled that a tax on INCOME from property (in the form of rents, dividends or interest) was required to be apportioned and that, since the 1894 Act did not provide for an apportionment of such taxes, the Act was unconstitutional. In effect, although all federal income taxes had theretofore been considered excises (indirect taxes) the Court treated a particular kind of income tax as a direct tax -- meaning that this kind of tax had to be apportioned.

Bravo. Why did they rule it needed to be apportioned? Maybe, just maybe, because real property is only subject to direct taxation and the requirement of apportionment?

The tax laws tried to tax the proceeds from a source that was only taxable under direct taxation, thus the court used substance instead of form to rule that Congress tried to tax indirectly without apportionment something which required apportionment and was subject to direct taxation ONLY.

His property was not taxable under the act. I did not mean NOT taxable at all.

You guys are really good at swallowing your own BS.

No, you're the one whose pushing the BS.

Now you admit that you understand that his "property was not taxable under the act." After I corrected you.

Bravo.

Ain't as easy as you thought it would be?

Welcome to the big league, kiddo.

[stija]

The fact that a tax has collateral regulatory effects is irrelevant.

Keep saying that to yourself buddy. Imagine Congress taxing liquor 1000$ per bottle tomorrow. I'm sure you'd change your tune as to how that is not to regulate.

Now the discussions between you and me are over ok? We have agreed to disagree so you can stop posting in response to me from now. I won't bother you again.

No, you're the one whose pushing the BS.

Now you admit that you understand that his "property was not taxable under the act." After I corrected you.

Because the scope of our discussion pertained to SEC regulation of the stock market and situation in Libya right? And not the relevant case and argument......you are sad bro.

Bravo.

Ain't as easy as you thought it would be?

Welcome to the big league, kiddo.

Corrected me? I'll take your post as, "I have no reply so i'll make fun of him."

Piss off to your hole and lick the US gov't hand that feeds you.

[Famspear]

And here it is again:

If you work for a federal or state government agency of ANY KIND WHATSOEVER, your gross earnings from the agency are includible in income under section 61 of the Internal Revenue Code of 1986 and, under the 1986 Code, there is no exclusion with respect to those earnings based on the concept of "intergovernmental tax immunity".

So, is this a correct statement of law or not? Come on, Einstein. Give us your wisdom.

If you feel it's not a correct statement of the law, go look for a federal court decision rendered after August 16, 1954 where the court ruled contrary to that statement.

Don't take too long.

[stija]

And here it is again:

If you work for a federal or state government agency of ANY KIND WHATSOEVER, your gross earnings from the agency are includible in income under section 61 of the Internal Revenue Code of 1986 and, under the 1986 Code, there is no exclusion with respect to those earnings based on the concept of "intergovernmental tax immunity".

So, is this a correct statement of law or not? Come on, Einstein. Give us your wisdom.

If you feel it's not a correct statement of the law, go look for a federal court decision rendered after August 16, 1954 where the court ruled contrary to that statement.

Don't take too long.

Ignored.

[Famspear]

Corrected me? I'll take your post as, "I have no reply so i'll make fun of him."

Piss off to your hole and lick the US gov't hand that feeds you.

Oh, what's-a-matter? Did our widdle biddy feewlins' get hurt? Are we a widdle embawwassed?

At first, the idea of coming to Quatloos seemed like such a swell concept, didn't it, "stija"?

It turns out that it ain't so easy when you deal with people who actually know the law you pretend to believe you understand.

Well, boo-hoo!



Next time, do your homework.

[wserra]

You quote a case dealing with a federal corporation for profit where the burden imposed was only on the taxpayer, a resident of New York. You quoted an irrelevant thing.
...
In your case there was ABSOLUTELY no burden on the federal corporation man, do you get that?
...
There was NO such burden in your case.
...
should there be a burden it would JUSTIFY the clothing of immunity from the agency itself. Sorry LPC.
...
Don't quote me a case that does NOT impose a burden, because obviously your decision infers, that should there be a burden of any kind on the AGENCY itself, it would be unconstitutional.
...
Compare that to a provision in New York state law from LPC's case that imposed a requirement of payment ONLY on its resident, and NO burden WHATSOEVER on the federal corporation.

You're a joke LPC, just like you're friend Famspear.

Actually, Dan's right:

The rationale underlying Pollock and the general immunity for government contract income has been thoroughly repudiated by modern intergovernmental immunity caselaw. In Graves v. New York ex rel. O'Keefe, 306 U.S. 466, 59 S.Ct. 595, 83 L.Ed. 927 (1939), the Court announced: “The theory ... that a tax on income is legally or economically a tax on its source, is no longer tenable.” Id., at 480, 59 S.Ct., at 598. The Court explained:

“So much of the burden of a non-discriminatory general tax upon the incomes of employees of a government, state or national, as may be passed on economically to that government, through the effect of the tax on the price level of labor or materials, is but the normal incident of the organization within the same territory of two governments, each possessing the taxing power. The burden, so far as it can be said to exist or to affect the government in any indirect or incidental way, is one which the Constitution presupposes....”

Id., at 487, 59 S.Ct., at 601.

See also James v. Dravo Contracting Co., 302 U.S. 134, 160, 58 S.Ct. 208, 221, 82 L.Ed. 155 (1937) (the fact that a tax on a Government contractor “may increase the cost to the Government ... would not invalidate the tax”); Helvering v. Gerhardt, 304 U.S. 405, 424, 58 S.Ct. 969, 977, 82 L.Ed. 1427 (1938). The thoroughness with which the Court abandoned the burden theory was demonstrated most emphatically when the Court upheld a state sales tax imposed on a Government contractor even though the financial burden of the tax was entirely passed on, through a cost-plus contract, to the Federal Government. Alabama v. King & Boozer, 314 U.S. 1, 62 S.Ct. 43, 86 L.Ed. 3 (1941). The Court stated:

“The Government, rightly we think, disclaims any contention that the Constitution, unaided by Congressional legislation, prohibits a tax exacted from the contractors merely because it is passed on economically, by the terms of the contract or otherwise, as part of the construction cost to the Government. So far as such a nondiscriminatory state tax upon the contractor enters into the cost of the materials to the Government, that is but a normal incident of the organization within the same territory of two independent taxing sovereignties. The asserted right of the one to be free of taxation by the other does not spell immunity from paying the added costs, attributable to the taxation of those who furnish supplies to the Government and who have been granted no tax immunity. So far as a different view has prevailed, we think it no longer tenable.”

Id., at 8-9, 62 S.Ct., at 45-46 (citations omitted).

King & Boozer thus completely foreclosed any claim that the nondiscriminatory imposition of costs on private entities that pass them on to States or the Federal Government unconstitutionally burdens state or federal functions. Subsequent cases have consistently reaffirmed the principle that a nondiscriminatory tax collected from private parties contracting with another government is constitutional even though part or all of the financial burden falls on the other government. [Citations omitted]

With the rationale for conferring a tax immunity on parties dealing with another government rejected, the government contract immunities recognized under prior doctrine were, one by one, eliminated.

South Carolina v. Baker, 485 U.S. 505, 520-522 (1988).

[Cpt Banjo]

The fact that a tax has collateral regulatory effects is irrelevant.

Keep saying that to yourself buddy. Imagine Congress taxing liquor 1000$ per bottle tomorrow. I'm sure you'd change your tune as to how that is not to regulate.

No, but I'd probably say that it was a penalty instead of a bona fide tax.

[Pottapaug1938]

The fact that a tax has collateral regulatory effects is irrelevant.

Keep saying that to yourself buddy. Imagine Congress taxing liquor 1000$ per bottle tomorrow. I'm sure you'd change your tune as to how that is not to regulate.

We actually have a precedent in US legal history. In 1937 (I believe), a law was enacted imposing a $200 per ounce tax on marijuana. Given the price of marijuana at the time, this was clearly a way of using the federal taxing power to wipe out the marijuana trade. No one ever was successful in overturning that tax.

[stija]

You quote a case dealing with a federal corporation for profit where the burden imposed was only on the taxpayer, a resident of New York. You quoted an irrelevant thing.
...
In your case there was ABSOLUTELY no burden on the federal corporation man, do you get that?
...
There was NO such burden in your case.
...
should there be a burden it would JUSTIFY the clothing of immunity from the agency itself. Sorry LPC.
...
Don't quote me a case that does NOT impose a burden, because obviously your decision infers, that should there be a burden of any kind on the AGENCY itself, it would be unconstitutional.
...
Compare that to a provision in New York state law from LPC's case that imposed a requirement of payment ONLY on its resident, and NO burden WHATSOEVER on the federal corporation.

You're a joke LPC, just like you're friend Famspear.

Actually, Dan's right:

The rationale underlying Pollock and the general immunity for government contract income has been thoroughly repudiated by modern intergovernmental immunity caselaw. In Graves v. New York ex rel. O'Keefe, 306 U.S. 466, 59 S.Ct. 595, 83 L.Ed. 927 (1939), the Court announced: “The theory ... that a tax on income is legally or economically a tax on its source, is no longer tenable.” Id., at 480, 59 S.Ct., at 598. The Court explained:

“So much of the burden of a non-discriminatory general tax upon the incomes of employees of a government, state or national, as may be passed on economically to that government, through the effect of the tax on the price level of labor or materials, is but the normal incident of the organization within the same territory of two governments, each possessing the taxing power. The burden, so far as it can be said to exist or to affect the government in any indirect or incidental way, is one which the Constitution presupposes....”

Id., at 487, 59 S.Ct., at 601.

See also James v. Dravo Contracting Co., 302 U.S. 134, 160, 58 S.Ct. 208, 221, 82 L.Ed. 155 (1937) (the fact that a tax on a Government contractor “may increase the cost to the Government ... would not invalidate the tax”); Helvering v. Gerhardt, 304 U.S. 405, 424, 58 S.Ct. 969, 977, 82 L.Ed. 1427 (1938). The thoroughness with which the Court abandoned the burden theory was demonstrated most emphatically when the Court upheld a state sales tax imposed on a Government contractor even though the financial burden of the tax was entirely passed on, through a cost-plus contract, to the Federal Government. Alabama v. King & Boozer, 314 U.S. 1, 62 S.Ct. 43, 86 L.Ed. 3 (1941). The Court stated:

“The Government, rightly we think, disclaims any contention that the Constitution, unaided by Congressional legislation, prohibits a tax exacted from the contractors merely because it is passed on economically, by the terms of the contract or otherwise, as part of the construction cost to the Government. So far as such a nondiscriminatory state tax upon the contractor enters into the cost of the materials to the Government, that is but a normal incident of the organization within the same territory of two independent taxing sovereignties. The asserted right of the one to be free of taxation by the other does not spell immunity from paying the added costs, attributable to the taxation of those who furnish supplies to the Government and who have been granted no tax immunity. So far as a different view has prevailed, we think it no longer tenable.”

Id., at 8-9, 62 S.Ct., at 45-46 (citations omitted).

King & Boozer thus completely foreclosed any claim that the nondiscriminatory imposition of costs on private entities that pass them on to States or the Federal Government unconstitutionally burdens state or federal functions. Subsequent cases have consistently reaffirmed the principle that a nondiscriminatory tax collected from private parties contracting with another government is constitutional even though part or all of the financial burden falls on the other government. [Citations omitted]

With the rationale for conferring a tax immunity on parties dealing with another government rejected, the government contract immunities recognized under prior doctrine were, one by one, eliminated.

South Carolina v. Baker, 485 U.S. 505, 520-522 (1988).

1. South Carolina did not incur a burden by using one bonds vs. the other. Same two prong test i quoted. Try again.
2. I do not care if YOU think Dan's right. Are you representative of the 5 member team of the SCOTUS? If affirmative, than i apologize.

We actually have a precedent in US legal history. In 1937 (I believe), a law was enacted imposing a $200 per ounce tax on marijuana. Given the price of marijuana at the time, this was clearly a way of using the federal taxing power to wipe out the marijuana trade. No one ever was successful in overturning that tax.

Are you actually agreeing with me for once?? One would have to argue that the 'penalty,' which it clearly is disguised as a tax, imposed an unconstitutionally permissible burden on him to overturn it. Otherwise it is a legit tax, if they have the right to tax in the first place.

[Pottapaug1938]

And here it is again:

If you work for a federal or state government agency of ANY KIND WHATSOEVER, your gross earnings from the agency are includible in income under section 61 of the Internal Revenue Code of 1986 and, under the 1986 Code, there is no exclusion with respect to those earnings based on the concept of "intergovernmental tax immunity".

So, is this a correct statement of law or not? Come on, Einstein. Give us your wisdom.

If you feel it's not a correct statement of the law, go look for a federal court decision rendered after August 16, 1954 where the court ruled contrary to that statement.

Don't take too long.

Ignored -- or, in other words (with fingers in ears) "La-la-la-la-la-I-can't-hear-you!"

Fixed it for you.

[Pottapaug1938]

" Are you representative of the 5 member team of the SCOTUS? If affirmative, than i apologize."

Another red herring. It's irrelevant whether he is or not. What IS relevant is whether he correctly states the holdings of the Court -- and, Sparky, given that he is a legal professional with many years of dealign with legal and tax questions, while you seem... shall we say, "self taught" , without any such experience, I'll go with LPC on this one.

[stija]

And here it is again:

If you work for a federal or state government agency of ANY KIND WHATSOEVER, your gross earnings from the agency are includible in income under section 61 of the Internal Revenue Code of 1986 and, under the 1986 Code, there is no exclusion with respect to those earnings based on the concept of "intergovernmental tax immunity".

So, is this a correct statement of law or not? Come on, Einstein. Give us your wisdom.

If you feel it's not a correct statement of the law, go look for a federal court decision rendered after August 16, 1954 where the court ruled contrary to that statement.

Don't take too long.

Ignored -- or, in other words (with fingers in ears) "La-la-la-la-la-I-can't-hear-you!"

Fixed it for you.

Thank you servant. Now be a good boi and post only when you have something to contribute that is not:

1. personal beliefs
2. religious nonsense
3. anything you think or have to say
4. incongruent with American Jurisprudence and well settled case law.

Another red herring. It's irrelevant whether he is or not. What IS relevant is whether he correctly states the holdings of the Court -- and, Sparky, given that he is a legal professional with many years of dealign with legal and tax questions, while you seem... shall we say, "self taught" , without any such experience, I'll go with LPC on this one.

You can go and do whatever you want. It changes not that he does not recognize that the SCOTUS opined that if there is an unconstitutional burden on the agency, the immunity is valid.

His case is irrelevant - so much for his lawyering skills.

You know nothing about me or what my profession is. I did not come here to boost my ego and self loathe. I came here to see what you guys know, and it is not much i can see that. A lot of gibberish and nonauthoritative opinions from members with 'professional degrees' who CHOOSE to disregard what the court clearly tells them.

I'll go with LPC on this one.

I get the hierarchy now.

[Cpt Banjo]

1. South Carolina did not incur a burden by using one bonds vs. the other. Same two prong test i quoted. Try again.

Of course it did. The obvious advantage of tax-exempt status for a State's bonds is that it can issue them at a lower interest rate compared to bonds whose interest is taxable. Removing the tax exemption increases the State's borrowing costs.

[stija]

1. South Carolina did not incur a burden by using one bonds vs. the other. Same two prong test i quoted. Try again.

Of course it did. The obvious advantage of tax-exempt status for a State's bonds is that it can issue them at a lower interest rate compared to bonds whose interest is taxable. Removing the tax exemption increases the State's borrowing costs.

TEFRA § 310 thus clearly imposes no direct tax on the States. The tax is imposed on and collected from bondholders, not States, and any increased administrative costs incurred by States in implementing the registration system are not "taxes" within the meaning of the tax immunity doctrine. See generally United States v. Mississippi Tax Comm'n, 421 U. S. 599, 421 U. S. 606 (1975) (describing tax as an enforced contribution to provide for the support of government). Nor does § 310 discriminate against States. The provisions of § 310 seek to assure that all publicly offered long-term bonds are issued in registered form, whether issued by state or local...

What are you on man?? You can read right?

Are you ever gonna have a rational discussion with me or are you going to make stuff up like Famspear?