Cargo containers

From the 2024 DOR Tax Exemption Study

total amount of $. . . . Document No. . . . issued June 11, 2012, includes assessments of public utility tax of $. . . , delinquency penalty of $. . . , and interest of $. . . , for a total amount of $. . . . Det. No. 12-0344, 32 WTD 302 (December 31, 2013) 305 [1] The taxpayer asserts that its income from contract mail transportation services is exempt from PUT because it is acting for the United States Postal Service (USPS), a federal agency. The Supremacy Clause of the United States Constitution, U.S. Const., Art. VI, cl. 2, has been interpreted to preclude a state from imposing a tax “when the levy falls on the United States itself, or on an agency or instrumentality so closely connected to the Government that the two cannot realistically be viewed as separate entities, at least insofar as the activity being taxed is concerned." United States v. New Mexico, 455 U.S. 720, 735, 102 S.Ct. 1373 (1982); United States v. City of Spokane, 918 F.2d 84, 86-87 (1990). The United States Supreme Court has repeatedly held that mail carriers contracted with the USPS for the delivery of U.S. mail are not immune from state taxation on the basis that they are federal instrumentalities. Alward