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Kagan's opinion for the Court held that a car-ownership allowance for Chapter 13 debtors to shield an expense-related portion of their income from creditors was not available to debtors who owned their car outright and thus did not make loan or lease payments. The Court based its ruling on the statutory language that such allowances must be "applicable" to the debtor, and in its view, therefore, must relate to an expense the debtor actually has; and on commentary authored by the Internal Revenue Services that explained the cost allowance tables expressly incorporated by the statute.
The Court held that CSX Transportation could sue the state over a diesel tax that applied to rail carriers, but from which interstate motor and water carriers were exempt.