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Goldberg v. Sweet

Supreme Court of the United States (1989) | 102 L. Ed. 2d 607; 109 S. Ct. 582; 488 U.S. 252; 1989 U.S. LEXIS 308; 65 Rad. Reg. 2d (P & F) 1402; 98 P.U.R.4th 263; 57 U.S.L.W. 4070

3 min read

TL;DR: The Supreme Court upheld an Illinois tax on interstate phone calls charged to an in-state service address, finding it did not violate the Commerce Clause because its structure, including a tax credit, prevented multiple taxation and was a practical approach for the modern telecommunications industry.

Legal Significance: This case adapted the Complete Auto test for intangible, non-geographic commerce, holding that a tax is fairly apportioned if it is internally and externally consistent and includes a credit provision to prevent actual multiple taxation, thereby avoiding rigid mileage-based formulas.