CSX Transp., Inc. v. AL Dept. of Revenue, et al., No. 12-14611 (11th Cir. 2013)
Annotate this CaseCSX, an interstate rail carrier, filed suit challenging Alabama's sales and use taxes. At issue was whether exempting CSX's main competitors from Alabama's sales tax was discriminatory as to rail carriers in violation of the Railroad Revitalization and Regulation Reform Act of 1976 (4-R Act), 49 U.S.C. 11501(b)(4). After establishing a comparison class of competitors and showing that its competitors did not pay the sales tax on diesel fuel purchases, CSX made a prima facie showing of discrimination under section 11501(b)(4). Alabama then failed to meet its burden by showing a "sufficient justification" for the exemptions. Accordingly, the court reversed the judgment of the district court, holding that Alabama's sales tax violated the 4-R Act, and remanded to the district court with instructions to enter declaratory and injunctive relief in favor of CSX.
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