Housatonic Railroad Company, Inc. v. Commissioner of Revenue Services

Summary

The court affirmed dismissal of the railroad's refund action on sovereign-immunity and subject-matter-jurisdiction grounds. It held that the federal railroad antidiscrimination statute reaches discriminatory petroleum taxes but authorizes only prospective injunctive or declaratory relief, not refunds of taxes already paid; under state law, the railroad was not a statutory taxpayer and could not use the general tax appeal provision to avoid the specific petroleum-tax appeal statute. Eveleigh, J., dissenting, would have allowed the railroad to appeal under the general statute as an aggrieved company.