Complete Auto Transit, Inc. v. Brady

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In Complete Auto Transit, Inc. v. Brady, 430 U.S. 274, 279 (1977), the U.S. Supreme Court established a framework under the Commerce Clause whereby it "has sustained a tax against Commerce Clause challenge when the tax is applied to an activity with a substantial nexus with the taxing State, is fairly apportioned, does not discriminate against interstate commerce, and is fairly related to the services provided by the State."