Tax Law—Railroads May Not Challenge a State’s Valuation Methodologies for Ad Valorum Tax Purposes Under the 4-R Act—CSX Transportation, Inc. v. State Board of Equalization, 472 F.3d 1281 (11th Cir. 2006)

Section 306 of the Railroad Revitalization and Regulatory Reform Act of 1976 (4-R Act) prohibits states from discriminatorily taxing railroad property.  The 4-R Act creates an exception to the Tax Injunction Act (TIA) by granting federal courts jurisdiction to hear cases in which railroad companies allege tax discrimination by states.  In CSX Transportation, Inc. v. State Board of Equalization, the Eleventh Circuit Court of Appeals considered whether, under the 4-R Act, a railroad company may challenge the valuation methodologies a state uses for ad valorum tax purposes.  The Eleventh Circuit ruled that a party may not challenge a state’s valuation methodologies in federal court because Congress failed to unequivocally demonstrate its intent to allow such a challenge. . . .