May Trucking Company v. Oregon Department of Transportation

In this case of first impression, we hold that the Tax Injunction Act, 28 U.S.C. § 1341 , applies to the International Fuel Tax Agreement (IFTA), a multi-jurisdic-tional taxation program in which one state collects taxes imposed by other states. We further hold that a taxpayer has a “plain, speedy and efficient remedy” within the meaning of the Tax Injunction Act so long as it may obtain a full and fair hearing in the courts of the state whose tax that taxpayer challenges. Accordingly, we affirm the decision of the district court, which held that the Tax Injunction Act deprives the court of subject matter jurisdiction to hear this claim that IFTA precludes Oregon’s collection of certain fuel taxes.

BACKGROUND

A. Oregon’s participation in IFTA

The International Fuel Tax Agreement is a “multi-jurisdictional agreement that is intended to ‘encourage cooperation in the administration and collection of motor fuel use tax.’ ” Hi-Way Dispatch, Inc. v. Ind. Dep’t of State Revenue, 756 N.E.2d 587, 594 (Ind. T.C.2001) (quoting Owner-Operator Indep. Drivers Ass’n v. State, 725 N.E.2d 891, 892 (Ind.Ct.App.2000)). IFTA itself imposes no taxes. “Rather, its member jurisdictions impose the…