Dollar Bank, FSB v. Harris

Summary

The court held that Ohio's financial-institutions tax does not violate the dormant Commerce Clause because its apportionment formula taxes only the portion of a bank's equity capital attributable to Ohio and would not cause multiple taxation if adopted by every state. The court rejected Dollar Bank's argument that the tax's regressive rates impermissibly burden interstate businesses by producing a higher aggregate tax than an exclusively Ohio business, and it summarily rejected the repackaged Due Process Clause challenge. The court affirmed the Board of Tax Appeals' decision upholding the tax commissioner's denial of Dollar Bank's refund request.