Court Case: Itel Containers Int’l Corp v. Huddleston

Question 1

What parties were involved in the case?

Answer 1

• Itel (Lessor of cargo containers)
• Huddleston (TN DOR)
• US Supreme Court

Question 2

what year did the case take place in?

Answer 2

1992

Question 3

What were the facts of the case?

Answer 3

• Itel leased cargo containers for use in international shipping
• Itel paid tax on lease of containers delivered in TN, then later filed a refund under Supremacy, Commerce, and Import/Export Clause
• The tax being imposed was on “discrete events” in TN

Question 4

What was the decision of the case?

Answer 4

• Supreme Court approved the tax, said it met all 4 prongs, and didn’t violate any of the 3 clauses that Itel was stating it did bc the tax was imposed on the transfer of title within the state.

Question 5

Which 3 tax concepts were at the forefront of this case?

Answer 5

• Supremacy Clause
• Commerce Clause
• Import-Export Clause

Question 6

What was the significance of the case?

Answer 6

The case stablished a 3 prong test used for foreign commerce.

Question 7

What was the 3 prong test that was established in this case?

Answer 7

• 4 prong test
• No risk of international double taxation
• No interference in US gov. regulation of interstate commerce