452
Opinion of Breyer, J.
(public utilities); § 40-21-57 (railroad operators); § 40-21-60 ("express" shipping companies).
These many exceptions to the ordinance mean that individuals with identical pay earned from work performed within Jefferson County will pay very different amounts in license fees. Such differences are not surprising where occupational licensing fees are at issue, as different license charges with different legislative pedigrees and applied to different industries often vary dramatically one to the next. Cf. Ohio Oil Co. v. Conway, 281 U. S. 146, 159 (1930) (State "may impose different specific taxes upon different trades and professions and may vary the rates of excise upon various products" without violating the Fourteenth Amend-ment's Equal Protection and Due Process Clauses). But I am not aware of any income tax that would produce such widespread differences in the tax owed by persons with identical incomes. Nor can Jefferson County separate its own tax from the rest of the State's licensing system by claiming that its own tax is different in kind. It would not make sense for a county income tax to exempt an engineer entirely, simply because he had paid the State $20 for a license; at most a county income tax might provide a $20 deduction from, or credit against, the amount of income tax due to the county. But, of course, if the county's tax is simply another licensing fee, then this structure makes sense. The engineer does not pay the county anything at all, because he has already paid a licensing fee to the State; the county charge would be redundant. The empirical significance of these factors depends upon the makeup of the work force in Jefferson County (e. g., to what extent is Jefferson County made up of bedroom communities whose residents work elsewhere), a matter about which the record tells us nothing.
Fourth, Jefferson County's ordinance directly imposes upon the Federal Government (the federal official's employer) burdens that to a limited extent exceed those imposed by an ordinary state or local income tax. The ordi-
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