Indiana Department of State Revenue v. Farm Credit Services of Mid-America

I agree in large part with the majority’s account of tax immunity doctrine past and present. And the majority’s result is inviting. As the majority explains, PCAs enjoy only limited immunity from state and local taxation, but FLBAs enjoy complete immunity. One can imagine that an ACA, as the product of a merger of these two, might enjoy tax immunity for those activities traditionally conducted by FLBAs, but not for those historically performed by PCAs. Nonetheless, it seems clear to me that Mid-America, as an ACA, is a new entity, albeit one formed by the merger of a PCA and an FLBA. Neither…