In Dep't of Revenue v. ACF Industries Inc., 510 U.S. 332, 114 S.Ct. 843, 127 L.Ed.2d 165 (1994), the Supreme Court held that "a State may grant exemptions from a generally applicable ad valorem property tax without subjecting the taxation of railroad property to challenge under the 4-R Act, 11501(b)(4)." Dep't of Revenue v. ACF Indus., Inc., 510 U.S. 332, 335, 114 S.Ct. 843, 127 L.Ed.2d 165 (1994). The Court concluded that section 11501 "does not limit the States' discretion to exempt nonrailroad property, but not railroad property, from ad valorem property taxes of general application." Id. at 347-48, 114 S.Ct. 843. The company in ACF Industries challenged Oregon's ad valorem tax on real and personal property on the ground that Oregon exempted various classes of goods from the tax, including motor vehicles, and instead charged such businesses a "modest annual registration fee." Id. at 335. 114 S.Ct. 843. Oregon thus "exempted certain classes of commercial and industrial property while taxing railroad cars in full." Id. at 337, 114 S.Ct. 843. The Supreme Court analyzed the challenged tax under section (b)(4) for discrimination. Id. at 335, 114 S.Ct. 843. Because, under the 4-R Act's plain language, sections (b)(1)-(3) did not contemplate outlawing exemptions from generally applicable property taxes, the Court reasoned, (b)(4) could not either - "Congress placed exempt property beyond the reach of subsections (b)(1)-(3) and therefore it would be illogical to conclude that Congress ... would turn around and nullify its own choice in subsection (b)(4)." Id. at 343, 114 S.Ct. 843.11 In ACF Industries, the Supreme Court primarily relied upon the plain language and structure of the 4-R Act, but "other considerations" buttressed its analysis. Id. at 343, 114 S.Ct. 843. First, the Court noted that the 4-R Act, while specifically addressing other types of discriminatory taxes, "does not speak with any degree of particularity to the question of tax exemptions." Id. Congress could clearly have prohibited such exemptions, but did not. Id. at 344, 114 S.Ct. 843. Second, the Court emphasized the traditional power of the states in providing exemptions from property taxes as "an important aspect of state and local tax policy." Id. Indeed, "it was common at the time 11501 was drafted, as it is now, for States with generally applicable ad valorem property taxes to exempt various classes of commercial property." Id. Congress's "silence on the subject ... reflects a determination to permit the States to leave their exemptions in place." Id. Third, the Court determined that "principles of federalism" in fact compelled its reading of the 4-R Act, because "when determining the breadth of a federal statute that impinges upon or pre-empts the States' traditional powers, the Court is hesitant to extend the statute beyond its evident scope." Id. at 345, 114 S.Ct. 843.