456
Opinion of Breyer, J.
in that "area." 4 U. S. C. § 106(a) (emphasis added). The Buck Act seeks to prevent a person who lives or works in a federal area from making a certain kind of legal defense to taxation, namely, the defense that the State lacks jurisdiction to impose an income tax upon a person who lives or works in such an area.
The Buck Act's very next phrase makes clear that the Act is limited so as to accomplish only the purpose I have just described. It says that the state or local
"taxing authority shall have full jurisdiction and power to levy and collect such tax in any Federal area . . . to the same extent and with the same effect as though such area was not a Federal area." Ibid. (emphasis added). And the Buck Act adds that in any event, it "shall not be deemed to authorize the levy or collection of any tax on . . . the United States." § 107(a). Thus, the Buck Act's own language indicates that the Act is not intended to alter the contours of the intergovernmental tax immunity doctrine itself.
The case before us falls outside the Buck Act because no one here has asked to "be relieved" of tax liability "by reason of his residing within a Federal area or receiving income from . . . services performed in such area." § 106(a). Rather, the respondents claim that Jefferson County's ordinance is unconstitutional, not by reason of the federal nature of where they work, but by reason of the federal nature of what they do. And for the reasons discussed above, the county's ordinance would violate the intergovernmental tax immunity doctrine whether or not the respondents lived or worked in a federal area. The Buck Act cannot help the county's claim because it gives the State power to tax income earned in a federal area only "to the same extent" and "with the same effect as," not to a greater extent than, if that income were earned elsewhere. Ibid. Indeed, for the reasons I discussed earlier, Jefferson County's tax falls outside the Act because it is a "tax on . . . the United States." § 107(a).
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