General Motors Corp. v. Tracy

The State of Ohio imposes its general sales and use taxes on natural gas purchases from all sellers, whether in-state or *282out-of-state, except regulated public utilities that meet Ohio’s statutory definition of a “natural gas company.” The question here is whether this difference in tax treatment between sales of gas by domestic utilities subject to regulation and sales of gas by other entities violates the Commerce Clause or Equal Protection Clause of the Constitution. We hold that it does not.

I

During the tax period at issue,1 Ohio levied a 5% tax on the in-state sales of goods, including…