In a year in which the Supreme Court has considered an extraordinary number of
constitutional challenges to state taxation, perhaps the term's most important and eagerly awaited
state tax decision was Quill Corp. v. North Dakota. In the weeks since the Quill decision was
anounced, most commentary has focused on its bald holding -- the Court's reaffirmation of the rule,
first stated in National Bellas Hess, Inc. v. Department of Revenue, that state and local
governments may impose use tax collection obligations only on those out-of-state mail-order sellers
that maintain a physical presence in the taxing jurisdiction.

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