United States v. International Business Machines Corp., 517 U.S. 843, 32 (1996)

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874

UNITED STATES v. INTERNATIONAL BUSINESS

MACHINES CORP.

Kennedy, J., dissenting

ginseng and ship masts would shift the tax burden abroad, and taxes on skins, beavers, and other raw materials might encourage American manufactures); id., at 361 (Mr. Dickenson [sic]: suggesting exemption of certain articles from the Export Clause); id., at 362 (Mr. Fitzimmons: discussing duties imposed on wool by Great Britain). Proponents of the Export Clause also focused on taxes on goods. Id., at 307 (Mr. Mercer: a tax on exported goods encourages the raising of articles not meant for exportation); id., at 360 (Mr. Williamson: discussing taxation of North Carolina tobacco by Virginia); id., at 361 (Mr. Sherman: general prohibition on power to tax exports necessary because "[a]n enumeration of particular articles would be difficult invidious and improper"); id., at 363 (Colonel Mason: discussing Virginia tax on tobacco; Mr. Clymer: discussing middle States' apprehensions of taxes on products like wheat flour and provisions that, unlike tobacco and rice, were sold in competitive markets). Oliver Ellsworth of Connecticut even contended that he opposed export taxes in part because "there are indeed but a few articles that could be taxed at all; as Tobo. rice & indigo, and a tax on these alone would be partial & unjust." Id., at 360.

In interpreting constitutional restrictions on the taxing power, we must recall that the want of this power in the National Government was one of the great weaknesses of the Articles of Confederation. With its expenses outpacing revenues from requisitions from the States, the central Government had emptied its vaults by 1782 and soon defaulted on its substantial debt. R. Paul, Taxation in the United States 4-5 (1954). As the Convention records indicate, depriving the Federal Government of the power to tax even export goods was a contentious issue, given the concern that it would cut off a needed source of revenue as well as disable Congress from using export taxes as an instrument of policy. Madison's last-minute proposal that the Export Clause's total prohibition on taxing exports be replaced with a provision

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