In this episode of GeTtin’ SALTy, host Nikki Dobay welcomes distinguished professor Richard Pomp (University of Connecticut School of Law) for a discussion about the fair apportionment prong of the Complete Auto test. Specifically, the two discuss the fair apportionment of use taxes levied on mobile property, and the Ellingson v. South Dakota case. Professor Pomp provides an overview of South Dakota's application of the use tax in the case, and why that application seems to violate the constitutional requirement of fair apportionment. Nikki and the Professor also discuss the evolution of use taxes, their role as a backstop for sales taxes, and why the credit doesn’t always work. The podcast also explores the significance of the denial of certiorari by the Supreme Court and the practical implications for states and taxpayers on this issue moving forward. Finally, the two end with a lively debate about Shakespeare quotes!