8--RANTA 211-222
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NOTES 211 Tax Lawyer, Vol. 54, No. 1 NOTE THE HARBOR MAINTENANCE TAX AND THE CONSTITUTIONALITY OF TAXING CRUISE PASSENGERS AS COMMERCIAL CARGO UNDER THE EXPORT CLAUSE: CARNIVAL CRUISE LINES, INC. V. UNITED STATES In Carnival Cruise Lines, Inc. v. United States,1 the Federal Circuit held that the Harbor Maintenance Tax (the HMT), as applied to cruise ship passengers, does not violate the Export Clause of the United States Constitution. Previously, in United States v. United States Shoe Corporation...