Cite as: 514 U. S. 175 (1995)
Opinion of the Court
F. 3d 90 (1994). The Court of Appeals held that Oklahoma's tax was not fairly apportioned, as required under the established test for the constitutionality of a state tax on interstate commerce. See Complete Auto Transit, Inc. v. Brady, 430 U. S. 274, 279 (1977). The Court of Appeals understood its holding to be compelled by our decision in Central Greyhound Lines, Inc. v. Mealey, 334 U. S. 653 (1948), which held unconstitutional an unapportioned state tax on the gross receipts 3 of a company that sold tickets for interstate bus travel. The Court of Appeals rejected the Commission's position that the sale of a bus ticket is a wholly local transaction justifying a sales tax on the ticket's full value in the State where it is sold, reasoning that such a tax is indistinguishable from the unapportioned tax on gross receipts from interstate travel struck down in Central Greyhound. 15 F. 3d, at 92- 93. We granted certiorari, 512 U. S. 1204 (1994), and now reverse.
II
Despite the express grant to Congress of the power to "regulate Commerce . . . among the several States," U. S. Const., Art. I, § 8, cl. 3, we have consistently held this language to contain a further, negative command, known as the dormant Commerce Clause, prohibiting certain state taxation even when Congress has failed to legislate on the subject. Quill Corp. v. North Dakota, 504 U. S. 298, 309 (1992); Northwestern States Portland Cement Co. v. Minnesota, 358 U. S. 450, 458 (1959); H. P. Hood & Sons, Inc. v. Du Mond, 336 U. S. 525, 534-535 (1949); cf. Gibbons v. Ogden, 9 Wheat. 1, 209 (1824) (Marshall, C. J.) (dictum). We have understood this construction to serve the Commerce Clause's purpose of
3 We follow standard usage, under which gross receipts taxes are on the gross receipts from sales payable by the seller, in contrast to sales taxes, which are also levied on the gross receipts from sales but are payable by the buyer (although they are collected by the seller and remitted to the taxing entity). P. Hartman, Federal Limitations on State and Local Taxation §§ 8:1, 10:1 (1981).
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