792
Opinion of the Court
out of the question in this case. New York, for example, has been in no position to establish towns, roads, or public buildings, see Michigan v. Wisconsin, 270 U. S., at 306-307; Maryland v. West Virginia, 217 U. S. 1, 40 (1910), or otherwise actually occupy the area of the Island in dispute, see Georgia v. South Carolina, supra, at 393 (charging Georgia with the knowledge that South Carolina was cultivating the territory in question). Instead, the United States Army Corps of Engineers and the Procurement Division of the Treasury Department controlled all construction and improvements. Nor did New York enjoy any substantial opportunity to assess taxes on the land and activities on the Island, and so generate the kind of evidence of prescription that we have found particularly persuasive in prior cases. See Illinois v. Kentucky, 500 U. S., at 385; Georgia v. South Carolina, supra, at 392; Arkansas v. Tennessee, supra, at 567; Maryland v. West Virginia, supra, at 40-41; Virginia v. Tennessee, 148 U. S., at 515. Until the passage of the Buck Act, ch. 787, 54 Stat. 1059,12 in 1940, no State or municipality could impose taxes in a federal area located within that State or municipality, and there is no evidence that New York collected any taxes from activities taking place on the Island until 1991, long after the possible prescription period was over. Nor was there any significant opportunity for New York to grant land or register deeds to land on the Island, actions that have produced evidence in prior cases
12 The Buck Act provides that "[n]o person shall be relieved from liability for payment of, collection of, or accounting for any sales or use tax levied by any State, or by any duly constituted taxing authority therein, having jurisdiction to levy such a tax, on the ground that the sale or use, with respect to which such tax is levied, occurred in whole or in part within a Federal area; and such State or taxing authority shall have full jurisdiction and power to levy and collect any such tax in any Federal area within such State to the same extent and with the same effect as though such area was not a Federal area." 4 U. S. C. § 105(a). The definition of "Federal area" under the Act includes "any lands or premises held or acquired by or for the use of the United States or any department, establishment, or agency, of the United States." § 110(e).
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