62
Opinion of the Court
an opinion concurring in part and concurring in the judgment, post, p. 78. Blackmun, J., filed a dissenting opinion, post, p. 82.
Philip W. Collier argued the cause for petitioner. With him on the briefs were Andrew L. Frey, Charles Rothfeld, and Lisa D. Leach.
Charles W. Burson, Attorney General of Tennessee, argued the cause for respondent. With him on the brief were John Knox Walkup, Solicitor General, and Daryl J. Brand, Assistant Attorney General.
Edwin S. Kneedler argued the cause for the United States as amicus curiae urging affirmance. On the brief were Solicitor General Starr, Acting Assistant Attorney General Bruton, Deputy Solicitor General Wallace, Kent L. Jones, Gary R. Allen, and Ernest J. Brown.*
Justice Kennedy delivered the opinion of the Court. In this case we consider the validity of a state tax affecting cargo containers used in international trade, a subject we have addressed once before. See Japan Line, Ltd. v. County of Los Angeles, 441 U. S. 434 (1979). We sustain Tennessee's sales tax on leases of containers owned by a domestic company and used in international shipping.
I
The use of large steel containers to transport goods by truck, rail, and oceangoing carrier was a major innovation in transportation technology. In 1990, the United States shipped, by value, 60% of its marine imports and 52% of its marine exports in these containers. Itel Containers Inter-*Briefs of amici curiae urging reversal were filed for the United Kingdom of Great Britain and Northern Ireland by William Karas and David H. Coburn; for Asia North America Eastbound Rate Agreement et al. by Stanley O. Sher and David F. Smith; and for the Institute of International Container Lessors et al. by Thomas S. Martin and Edward A. Woolley. R. Frederic Fisher, Barry J. London, and Lawrence N. Minch filed a brief for the Pacific Merchant Shipping Association et al. as amici curiae.
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