Cite as: 514 U. S. 175 (1995)
Breyer, J., dissenting
which cases, for example, permit one State to impose a severance tax and another a sales tax on the same physical item (say, coal). In my view, however, the analogy to sales taxes is not as strong as the analogy to the tax at issue in Central Greyhound. After all, the tax before us is not a tax imposed upon a product that was made in a different State or was consumed in a different State or is made up of ingredients that come from a different State or has itself moved in interstate commerce. Rather, it is a tax imposed upon interstate travel itself—the very essence of interstate commerce. And, it is a fairly obvious effort to tax more than "that portion" of the "interstate activity['s]" revenue "which reasonably reflects the in-state component." Goldberg v. Sweet, supra, at 262. I would reaffirm the Central Greyhound principle, even if doing so requires different treatment for the inherently interstate service of interstate transportation, and denies the possibility of having a single, formal constitutional rule for all self-described "sales taxes." The Court of Appeals wrote that this "is a classic instance of an unapportioned tax" upon interstate commerce. In re Jefferson Lines, Inc., 15 F. 3d 90, 93 (CA8 1994). In my view, that is right. I respectfully dissent.
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