Bodman v. SCDOR
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In an original jurisdiction action, Petitioner alleged that the sheer number of exemptions to and caps on South Carolina's sales and use tax removed any rational relationship they have to the underlying tax itself. He therefore requested that the Supreme Court strike down all of the exemptions and caps as being unconstitutional, leaving behind only the imposition of the tax. In particular, Petitioner contended that the entire exemption and cap scheme violated the State constitution's equal protection guarantee and prohibition against special legislation. The Court disagreed, finding that Petitioner did not meet his burden of proof. "We emphasize that our holding rests solely on the fact that [Petitioner's] challenge is to the number of caps and exemptions and not whether individual ones would withstand constitutional scrutiny. Thus, nothing in our opinion today should be construed as precluding a challenge based on the content of individual caps and exemptions at a later date."
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