24
Opinion of Thomas, J.
comes with a dubious pedigree. In one of the cases cited in Allegheny Pittsburgh, Allied Stores, we upheld against an equal protection challenge a statute that exempted some corporations from ad valorem taxes imposed on others. Not only does Allied Stores not even hint that the Constitution "require[s] . . . the seasonable attainment of a rough equality in tax treatment of similarly situated property owners," 488 U. S., at 343, we took pains there to stress a very different proposition:
"The States have very wide discretion in the laying of their taxes. . . . Of course, the States, in the exercise of their taxing power, are subject to the requirements of the Equal Protection Clause of the Fourteenth Amendment. But that clause imposes no iron rule of equality, prohibiting the flexibility and variety that are appropriate to reasonable schemes of state taxation. The State . . . is not required to resort to close distinctions or to maintain a precise, scientific uniformity with reference to composition, use or value." Allied Stores, 358 U. S., at 526-527.
Two of the other cases cited in Allegheny Pittsburgh, Sunday Lake Iron and Sioux City Bridge, also rejected equal protection challenges, see also Charleston Fed. Sav. & Loan Assn. v. Alderson, 324 U. S. 182 (1945), and the case in which the words intentional, systematic, and undervaluation first appeared, Coulter v. Louisville & Nashville R. Co., 196 U. S. 599, 609 (1905), did not explain where the test came from or why.
It is true that we applied the rule of Coulter to strike down a tax system in Cumberland Coal, also cited in Allegheny Pittsburgh. Cumberland Coal, however, reflects the most serious of the problems with respondents' reading of Allegheny Pittsburgh. As respondents understand these two cases, their rule is categorical: A tax scheme violates the Equal Protection Clause unless it provides for "the sea-
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