J.C. Penney National Bank v. Johnson

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that the physical presence of 11,000 to 17,000 accounts of the bank’s credit cards failed to satisfy the physical-presence requirement of the Commerce Clause under Quill
• holding that Tennessee may not impose franchise and excise tax on a company not physically present in Tennessee
• “Any constitutional distinctions between the franchise and excise taxes presented here and the use taxes contemplated in Bellas Hess and Quill are not within the purview of this court to discern.”
• “Both Bellas Hess and Quill are clear in their holding that in the context of a use tax, physical presence is required in order to satisfy the substantial nexus requirement of Complete Auto.”
• applying physical presence test to franchise and excise taxes

Source: CourtListener parenthetical corpus (CC0).