Alico, LLC v. Somers

Summary

The court held that Connecticut's motor vehicle property tax, applied to vehicles that most frequently leave from and return to Somers, does not violate the dormant Commerce Clause. Applying the Complete Auto framework and the internal consistency test, the court concluded that identical laws in every state would tax each vehicle in only one state. Any double taxation resulted from the interaction of Connecticut's location-based tax and Massachusetts' registration-based tax, rather than from discrimination inherent in Connecticut's law.