Cite as: 522 U. S. 287 (1998)
Opinion of the Court
New York City to pursue their livelihood, "it being a matter of common knowledge that from necessity, due to the geographical situation of [New York City], in close proximity to the neighboring States, many thousands of men and women, residents and citizens of those States, go daily from their homes to the city and earn their livelihood there." Travis, 252 U. S., at 80. In attempting to justify the discrimination against nonresidents effected by § 631(b)(6), respondents assert that because the State only has jurisdiction over non-residents' in-state activities, its limitation on nonresidents' deduction of alimony payments is valid. Invoking Shaffer and Travis, the State maintains that it should not be required to consider expenses "wholly linked to personal activities outside New York." Brief for Respondent Commissioner of Taxation and Finance 24. We must consider whether that assertion suffices to substantially justify the challenged statute.
A
Looking first at the rationale the New York Court of Appeals adopted in upholding § 631(b)(6), we do not find in the court's decision any reasonable explanation or substantial justification for the discriminatory provision. Although the court purported to apply the two-part inquiry derived from Toomer and Piper, in the end, the justification for § 631(b)(6) was based on rationales borrowed from another case, Goodwin v. State Tax Comm'n, 286 App. Div. 694, 146 N. Y. S. 2d 172, aff 'd, 1 N. Y. 2d 680, 133 N. E. 2d 711 (1955), appeal dism'd, 352 U. S. 805 (1956). There, a New Jersey resident challenged New York's denial of deductions for real estate taxes and mortgage interest on his New Jersey home, and his medical expenses and life insurance premiums. The challenge in that case, however, was to a provision of New York tax law substantially similar to that considered in Travis, under which nonresident taxpayers were allowed deductions " 'only if and to the extent that, they are connected
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