Cite as: 507 U. S. 60 (1993)
Blackmun, J., dissenting
liberal interpretation is to be preferred.' " United States v. Stuart, 489 U. S. 353, 368 (1989), quoting Bacardi Corp. of America v. Domenech, 311 U. S. 150, 163 (1940); see also Nielsen v. Johnson, 279 U. S. 47, 51-52 (1929). This Court recognized in Japan Line, Ltd. v. County of Los Angeles, 441 U. S. 434 (1979), that the Container Conventions reflect a "national policy to remove impediments to the use of containers as 'instruments of international traffic.' " Id., at 453, quoting 19 U. S. C. § 1322(a); see Customs Convention on Containers, Dec. 2, 1972, [1975] 988 U. N. T. S. 43 (hereinafter 1972 Convention); Customs Convention on Containers, May 18, 1956, [1969] 20 U. S. T. 301, T. I. A. S. No. 6634 (hereinafter 1956 Convention). Tennessee's tax clearly frustrates that policy.
In concluding that Tennessee's tax is not prohibited, the majority studiously ignores the realities of container leasing. All petitioner's containers are dedicated to international commerce, which means that they spend no more than three months at a time in any one jurisdiction. See 1972 Convention, Art. 4; 1956 Convention, Art. 3. Furthermore, transferring containers to new lessees is an integral part of any container-leasing operation. A major advantage of leasing rather than owning a container is that a shipper may return the container to the lessor at or near the shipment destination without having to provide for the return transport of the container. J. Tan, Containers: The Lease-Buy Decision 13 (London, International Cargo Handling Co-ordination Association, 1983). The lessor then transfers the container to another shipper who needs to carry goods from that location or transports the container to another location where it is needed. Leased containers like those of petitioner are constantly crossing national boundaries and are constantly being transferred to new lessees at the ends of their journeys. Whether Tennessee taxes the act of importation or the act of transfer makes little difference with respect to leased containers. Each kind of tax imposes substantial "impediments
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