Chase Manhattan Bank v. Gavin

MCDONALD, J.,

with whom BERDON, J., joins, dissenting. I disagree with the majority’s conclusion that the imposition of Connecticut’s state income tax on the entire income of the trusts does not violate due process of law or the commerce clause of the United States constitution. I would hold that Connecticut’s attempt to tax the entire income, all of which was produced outside the state of Connecticut, violates both due process and the negative implications of the commerce clause.

“The Due Process and Commerce Clauses of the [United States] Constitution . . . prevent States that impose an…