Meadwestvaco Corp., Successor in Interest to Mead Corp. v. Illinois Department of Revenue

Summary

The Supreme Court vacated the judgment of the Illinois Appellate Court, which upheld a state tax on capital gains from the sale of a division without first finding a unitary business relationship. The Court held that the operational function test is not an independent ground for apportionment outside the unitary business principle. Justice Thomas concurred, expressing serious doubt that the Constitution permits the Court to adjudicate state taxation cases under the negative Commerce Clause.