296
Opinion of the Court
The court rejected petitioners' contention that the lack of legislative history explaining § 631(b)(6) was of any importance, finding that "substantial reasons for the disparity in tax treatment are apparent on the face of the statutory scheme." Ibid. The court also rejected petitioners' claims that § 631(b)(6) violates the Equal Protection and Commerce Clauses. Ibid. Those claims are not before this Court.
Recognizing that the ruling of the New York Court of Appeals in this case creates a clear conflict with the Oregon Supreme Court's decision in Wood v. Department of Revenue, 305 Ore. 23, 749 P. 2d 1169 (1988), and is in tension with the South Carolina Supreme Court's ruling in Spencer v. South Carolina Tax Comm'n, 281 S. C. 492, 316 S. E. 2d 386 (1984), aff 'd by an equally divided Court, 471 U. S. 82 (1985), we granted certiorari. 520 U. S. 1227 (1997). We conclude that, in the absence of a substantial reason for the difference in treatment of nonresidents, § 631(b)(6) violates the Privileges and Immunities Clause by denying only nonresidents an income tax deduction for alimony payments.
II
A
The object of the Privileges and Immunities Clause is to "strongly . . . constitute the citizens of the United States one people," by "plac[ing] the citizens of each State upon the same footing with citizens of other States, so far as the advantages resulting from citizenship in those States are concerned." Paul v. Virginia, 8 Wall. 168, 180 (1869). One right thereby secured is the right of a citizen of any State to "remove to and carry on business in another without being subjected in property or person to taxes more onerous than the citizens of the latter State are subjected to." Shaffer, supra, at 56; see also Toomer v. Witsell, 334 U. S. 385, 396 (1948); Ward v. Maryland, 12 Wall. 418, 430 (1871).
Of course, nonresidents may "be required to make a ratable contribution in taxes for the support of the govern-
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