Some examples of tax statutes that have been found to violate the commerce clause: In Boston Stock Exchange v. State Tax Comm'n (1977) 429 U.S. 318, the high court found New York's transfer tax on securities transactions violated the commerce clause, where transactions involving an out-of-state sale were taxed more heavily than most transactions involving a sale within the state. (Boston Stock Exchange, supra, 429 U.S. at p. 319; id. at pp. 334-335 "A State may no more use discriminatory taxes to assure that nonresidents direct their commerce to businesses within the State than to assure that residents trade only in intrastate commerce.".) In Bacchus Imports, Ltd. v. Dias (1984) 468 U.S. 263, the court found that an exemption from Hawaii's excise tax on sales of liquor at wholesale, for certain locally produced alcoholic beverages, discriminated against interstate commerce. (Bacchus, supra, 468 U.S. at pp. 273, 268, fn. 8, 269 exemption violated the commerce clause "because it had both the purpose and effect of discriminating in favor of local products"; "discrimination between in-state and out-of-state goods is as offensive to the Commerce Clause as discrimination between in-state and out-of-state taxpayers"; small volume and lack of present competitive threat were not dispositive of whether competition existed between locally produced and foreign beverages and it was "well settled that 'we need not know how unequal the Tax is before concluding that it unconstitutionally discriminates'".) In Armco Inc. v. Hardesty (1984) 467 U.S. 638, the court found that West Virginia's gross receipts tax on persons selling tangible property at wholesale, from which local manufacturers were exempt, discriminated against interstate commerce. (Id. at pp. 641, 644 "A tax that unfairly apportions income from other States is a form of discrimination against interstate commerce.".) In New Energy Co. of Indiana v. Limbach (1988) 486 U.S. 269, the court invalidated a tax credit (against the Ohio sales tax on fuel) for ethanol sold by fuel dealers, where the credit applied only if the ethanol was produced in Ohio (or a state granting similar tax advantages to ethanol produced in Ohio). (New Energy, supra, 486 U.S. at p. 271; id. at p. 278 "The Commerce Clause does not prohibit all state action designed to give its residents an advantage in the marketplace, but only action of that description in connection with the State's regulation of interstate commerce. Direct subsidization of domestic industry does not ordinarily run afoul of that prohibition; discriminatory taxation of out-of-state manufacturers does.".) In Oregon Waste Systems, Inc. v. Department of Environmental Quality of Ore. (1994) 511 U.S. 93, the high court invalidated an Oregon surcharge on the in-state disposal of solid waste generated in other states that was three times as high as the surcharge imposed on waste generated in Oregon, finding it "patently discriminatory." (Oregon Waste, supra, 511 U.S. at pp. 106, fn. 9, 108; id. at p. 99 "As we use the term here, 'discrimination' simply means differential treatment of in-state and out-of-state economic interests that benefits the former and burdens the latter.".)