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Opinion of the Court
tions—press releases, letters, and amicus briefs—on which Colgate here relies are merely precatory. Executive Branch communications that express federal policy but lack the force of law cannot render unconstitutional California's otherwise valid, congressionally condoned, use of worldwide combined reporting.32
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The Constitution does " 'not make the judiciary the overseer of our government.' " Dames & Moore v. Regan, 453 U. S. 654, 660 (1981), quoting Youngstown Sheet & Tube Co. v. Sawyer, 343 U. S., at 594 (Frankfurter, J., concurring). Having determined that the taxpayers before us had an adequate nexus with the State, that worldwide combined reporting led to taxation which was fairly apportioned, nondiscriminatory, fairly related to the services provided by the State, and that its imposition did not result inevitably in multiple taxation,
32 The Solicitor General suggests that when a court analyzes "whether a state tax impairs the federal government's ability to speak with one voice . . . the statements of executive branch officials are entitled to substantial evidentiary weight," Brief for United States as Amicus Curiae 19, but he argues that the constitutionality of a State's taxing practice must be assessed according to the federal policy, if any, in effect at the time the challenged taxes were assessed. He asserts that federal officials had not articulated a policy opposing use by the States of worldwide combined reporting prior to the mid-1980's, and urges the Court to affirm the judgments below on the ground that California's use of worldwide combined reporting was not unconstitutional during the years here at issue, even if it became unconstitutional in later years (a question on which he takes no position, see Tr. of Oral Arg. 38-41). Colgate, on the other hand, suggests that the relevant time frame is "when the tax is definitively enforced by the state taxing authority, through judicial proceedings if necessary, not when the tax technically accrues under state law," Reply Brief for Petitioner in No. 92-1839, p. 7, and argues in the alternative that a federal policy opposing combined worldwide reporting had been established as of 1970-1973, id., at 9. We need not resolve this dispute, because we have concluded that the Executive statements criticizing States' use of worldwide combined reporting do not, in light of Congress' acquiescence in the States' actions, authorize judicial intervention here.
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