Amicus Curiae Brief — Department of Taxation and Finance of NY v. Milhelm Attea & Bros.

eupromée Vout, U.S.

FILED

No. 93.37 7 |

IN THE

Supreme Court of the Gni

OCTOBER TERM, 1993

_ DEPARTMENT OF TAXATION AND FINANCE

OF THE STATE OF NEW YORK, et al.,

against Petitioners,

MILHELM ATTEA & Bros., INC.,

Respondent.

JAMES W. WETZLER, as Commissioner of Taxation

and Finance of the State of New York, et al.,

against Petitioners,

ELIAS ATTEA, JR.,

Respondent.

On Writ of Certiorari to the Court of Appeals

of the State of New York

BRIEF AMICI CURIAE OF NATIONAL ASSOCIATION

OF CONVENIENCE STORES, NEW YORK ASSOCIATION

OF CONVENIENCE STORES, INDEPENDENT

PETROLEUM MARKETERS OF NEW YORK, INC. AND

SOCIETY OF INDEPENDENT GASOLINE MARKETERS

OF AMERICA IN SUPPORT OF PETITIONERS

MARK L. AUSTRIAN

(Counsel of Record)

JASON M. BRANCIFORTE

COLLIER, SHANNON, RILL & Scott

3050 K Street, N.W., Suite 400

Washington, D.C. 20007

(202) 342-8400

Counsel for Amici Curiae

National Association of Convenience

Stores, New York Association Of

Convenience Stores, Independent

Petroleum Marketers Of New York,

Ine. and Society Of Independent

Gasoline Marketers Of America

December 16, 1993

PRESS OF BYRON S. ADAMS, WASHINGTON, D.C. (202) 347-8203

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TABLE OF CONTENTS

Page

TABLE OF AUTHORITIES .................. i

INTEREST OF AMICI CURIAE .........ccceee: 2

SUMMARY OF ARGUMENT ................. 6

a ee re 6

A. The New York Regulations Are Not

Preempted By The Indian Trader

Me 7

1. This Court Has Repeatedly

Upheld Similar Regulatory

DE ecededsevereasesees 7

2. The Court Of Appeals’

Decision Is Wrong .......... 10

B. The Regulations Impose Permissible

Minimal Burdens On Indian Traders .. 11

c. The New York Regulations Should Be

Upheld Because They Protect The

Valid Interests Of Amici And Other

Non-Indian Retail Businesses In Fair

PE Secevkeecewvseaeesse.s 13

DT Cccheevk hes dvesee ss bec eswens 15

TABLE OF AUTHORITIES

FEDERAL CASES

Moe v. Confederated Salish &

Kootenai Tribes, 425 U.S. 463 (1976) .. 6, 7, 11, 13

Oklahoma Tax Commission v. Citizen

Band Potawatomi Indian Tribe of Oklahoma,

496 US. SS (ISI) «0 scenes 6, 7, 9, 11

Warren Trading Post Co. v. Arizona

Tax Commission, 380 U.S. 685 (1965) ...... 7,8

Washington v. Confederated Tribes

of Colville Reservation,

447 US. 136 (19GB) . i cesccses eee passim

STATE CASES

Milhelm Attea & Bros., Inc. v. Department

of Taxation, 615 N.E.2d 994 (N.Y. 1993) ..... 10

MISCELLANEOUS

New York Comp. Codes R. & Regs. tit. 20,

§ 339S.6(f) and (@) ... ce cucteeene eee 12

New York Tax Law § 471(1) .............00008- 3

ite

No. 93-377

IN THE

SUPREME COURT OF THE UNITED STATES

OCTOBER TERM, 1993

DEPARTMENT OF TAXATION AND FINANCE

OF THE STATE OF NEW YORK, et al,

Petitioners,

against

MILHELM ATTEA & BROS., INC.,

Respondent.

JAMES W. WETZLER, as Commissioner of Taxation

and Finance of the State of New York, et al,

Petitioners,

against

ELIAS ATTEA, JP..,

Respondent.

On Writ of Certiorari to the Court of Appeals

of the State of New York

BRIEF AMICI CURIAE OF NATIONAL ASSOCIATION

OF CONVENIENCE STORES, NEW YORK

ASSOCIATION OF CONVENIENCE’ STORES,

INDEPENDENT PETROLEUM MARKETERS OF NEW

YORK, INC., AND SOCIETY OF INDEPENDENT

GASOLINE MARKETERS OF AMERICA IN SUPPORT

OF PETITIONERS

The National Association of Convenience Stores,

New York Association Of Convenience Stores, Independent

Petroleum Marketers Of New York, Inc. and Society Of

Independent Gasoline Marketers Of America submit this

vie

brief as Amici Curiae in support of petitioners James W.

Wetzler, Commissioner of Taxation and Finance of the

State of New York, and the Department of Taxation and

Finance of the State of New York.”

INTEREST OF AMICI CURIAE

The National Association of Convenience Stores,

founded in 1961, is a non-profit trade association

representing nearly 1,500 retailers operating convenience

Stores throughout the United States. These retailers

provide consumers with convenient locations to quickly

purchase a wide array of products and services, including

tobacco, soda, candy, baked goods and snack foods. Nearly

27 percent of the typical convenience store’s merchandise

sales are tobacco products. Consumers who initially go to

these stores to buy tobacco products typically make

additional impulse purchases of goods which they then

recognize they need. The convenience stores rely heavily

on these supplemental purchases. A significant number of

convenience stores are located near Indian reservations.

These stores are in direct competition with stores selling

tobacco products on these reservations.

| The New York Association of Convenience Stores

is a non-profit corporation representing the collective

interests of small retail businesses that sell cigarettes,

petroleum and other products in New York. The

Independent Petroleum Marketers of New York, Inc. is a

non-profit corporation that represents the interests of small

businesses that sell petroleum, cigarettes and other

L/ This brief is filed with the permission of the parties.

peer consents have been provided to the Clerk of this

ourt.

oMe

~~

products, primarily at retail, in New York State. The

Society of Independent Gasoline Marketers of America is

a national trade association representing independent

marketers and chain retailers of motor fuel in the United

States, most of whom operate convenience stores in

conjunction with their fuel outlets. Many of the businesses

that these groups represent compete for retail sales of

cigarettes to non-Indian consumers with businesses

operated by Indians on reservations.

New York Tax Law § 471(1) imposes an excise tax

on all cigarettes purchased in New York. The tax is paid

by the purchase of stamps affixed to the cigarette packages

as a precondition to the first taxable sale by a wholesaler

or distributor. The tax is added to the selling price of the

cigarettes along the distribution chain and is ultimately

added to the retail price charged the customer. The

members of the Amici collect these taxes from consumers

on their retail sales of cigarettes.

Because Indians and Indian tribes are exempt from

State taxation within their own territory, wholesale dealers

may sell them unstamped cigarettes. These cigarettes are

substantially cheaper than cigarettes purchased outside of

the reservation. Non-Indian purchasers are required to pay

the tax. However, it is well known that Indian sellers make

no attempt to collect this tax from non-Indian purchasers.

Consequently, many non-Indians travel to Indian

reservations to buy unstamped cigarettes and avoid the

sales tax. This widespread conduct threatens to destroy

businesses near the reservations who depend upon

purchases of tobacco and gasoline products to survive.

In an effort to prevent this pervasive evasion of the

sales tax, the New York State Commissioner of Taxation

oSe

and Finance adopted regulations designed to collect the tax

from non-Indian purchasers. These regulations will also

prevent Indian retailers from wrongfully using the tax

exemption and unfairly competing with stores outside the

reservations. Briefly, these regulations permit Indian

retailers to purchase an unlimited number of taxed

cigarettes, advancing the tax to their wholesale suppliers

and recovering the tax from the non-Indian purchaser. The

Indian retailers may also purchase untaxed cigarettes, for

resale to Indians, in an amount equal to the approximate

number of Indian consumers serviced by the retailer. The

wholesalers selling to the Indian retailers are required to

document their sales of untaxed cigarettes and collect "tax

exemption coupons" issued by the State for every purchase

of untaxed cigarettes by Indian retailers.

The Amici have a direct and vital economic interest

in the enforcement of the New York regulations, and

similar regulations throughout the country.” Retailers

represented by these associations compete with Indian

retailers for retail sales of cigarettes to non-Indian

consumers. Indian retailers have historically refused to

collect the applicable State taxes on cigarettes sold to non-

Indians and aggressively market their exemption from State

taxation to non-Indian purchasers by selling cigarettes at

inordinately low "discount" prices. These artificially low

prices divert non-Indian purchasers away from the stores

operated by non-Indian retailers near the reservations.

2/ A|list of other associations representing retailers across

the country who compete with on-reservation Indian

businesses for retail sales of cigarettes to non-Indian

purchasers, and who urge this Court to reverse the decision

of the New York State Court of Appeals, is set forth in the

Appendix to this brief.

att.

Non-Indian retailers lose significant revenue that would

have been generated by their cigarette sales but for the

Indian retailers’ illegal discounts. In fact, retailers in New

York, where the tax on cigarettes is currently 56 cents on

every package of 20 cigarettes, and across the country lose

millions of dollars in cigarette sales each year because of

the unlawful competitive advantage Indian retailers create

for themselves by refusing to collect the applicable State

tax.

The low-cost prices on cigarettes offered by Indian

retailers also seriously reduce the sales of other products

sold by the Amici’s members. Surveys indicate that the

average cigarette smoker purchases cigarettes from

convenience stores approximately three times per week.

This is more than three times the number of visits per week

by non-smokers. Moreover, as a result of the stores’

convenient geographic locations and extensive inventory of

goods, these cigarette smokers also purchase products such

as soft drinks, newspapers, magazines, coffee and bakery

items at the same time they purchase cigarettes. By

offering discount prices on cigarettes, Indian retailers lure

customers away from non-Indian retailers’ stores and

thereby decrease the amount of money these customers

spend on cigarettes and other products. The stores’ overall

revenue level declines and their profitability weakens. In

some cases, retailers located in close proximity to Indian

retailers have been forced to go out of business because of

this unfair competition.

Amici urge this Court to uphold the New York

regulations to protect the rights of their members and

enable them to compete on an equal basis with on-

reservation Indian retailers. Unless the New York

regulations are upheld, legitimate businesses who follow the

. ¥

law will continue to face unfair and inequitable competition

by Indian retailers who refuse to collect valid State taxes

from non-Indian purchasers of cigarettes.

SUMMARY OF ARGUMENT

The decision of the New York State Court of

Appeals should be overruled, and the constitutionality of

the New York regulations affirmed, because this Court’s

decisions in Moe v. Confederated Salish & Kootenai Tribes,

425 U.S. 463 (1976); Washington v. Confederated Tribes of

Colville Reservation, 447 U.S. 134 (1980); and Oklahoma

Tax Commission v. Citizen Band Potawatomi Indian Tribe of

Oklahoma, 498 U.S. 505 (1991), expressly authorize New

York’s regulations. Specifically, this trilogy of cases permits

the State to require retail outlets selling cigarettes on

Indian reservations and their wholesale suppliers to comply

with regulations which (1) limit the quantity of untaxed

cigarettes which Indian retailers may purchase; (2) require

Indian retailers to advance a tax to their wholesale

suppliers for the cigarettes purchased for resale to non-

Indian consumers; and (3) impose minimal recordkeeping

and reporting burdens on the retailers’ wholesale suppliers.

ARGUMENT

This Court has consistently held that states may

impose a tax on non-Indian purchasers of cigarettes from

Indian retail outlets, and may require the Indian retailers

to assist in collecting the tax. See Moe v. Confederated

Salish & Kootenai Tribes, 425 U.S. 463, 482-83 (1976);

Washington v. Confederated Tribes of Colville Reservation,

447 U.S. 134, 151 (1980). Moreover, these cases hold that

States can also require the wholesaler suppliers who sell

cigarettes to these Indian retailers to comply with state

” =

regulations whose purpose is to prevent non-Indian

consumers from evading the state tax. Oklahoma Tax

Commission v. Citizen Band Potawatomi Indian Tribe of

Oklahoma, 498 U.S. 505, 514 (1991). See also Colville, 447

U.S. at 159-61. The decision by the New York Court of

Appeals that New York’s regulations directed at wholesale

suppliers are preempted by the Indian trader laws and are

unconstitutionally bure»isome is flatly inconsistent with this

Court’s prior opinions.

A. The New York Regulations Are Not

Preempted By The Indian Trader Laws

1. This Court Has Repeatedly Upheld

Similar Regulatory Schemes

In Moe, the Court addressed a Montana law which

required Indian sellers of cigarettes to collect a state sales

tax imposed upon non-Indian cigarette purchasers. The tax

scheme required the Indian seller to pay the tax to the

wholesaler from whom it purchased the cigarettes, and then

add the tax to the purchase price of the cigarettes for

payment by the ultimate non-Indian purchaser. Moe, 425

U.S. at 482. The Court emphasized that nothing in the law

"runs afoul of any congressional enactment dealing with the

affairs of Indians” because the ultimate burden of the "tax"

was on the non-Indian purchaser. /d. at 483. The Court

distinguished Warren Trading Post Co. v. Anzona Tax

Commission, 380 U.S. 685 (1965), relied upon below by the

Court of Appeals, on the ground that the 2% tax levied by

the State of Arizona on gross sales by Indian traders to

reservation Indians was imposed directly on such sales and

not on the ultimate non-Indian consumer. The Court

expressly approved a regulatory scheme which was merely

a “minimal burden" on Indian retailers designed to prevent

SF

non-Indian purchasers from avoiding a concededly lawful

tax. Id.

The Court reaffirmed the principles announced in

Moe four years later in Colville, and expressly sanctioned a

state’s power to require the assistance of Indian retailers

and their wholesale suppliers to collect validly enacted state

taxes from non-Indians purchasing cigarettes on the

reservation. At issue in Colville was a Washington State

law which imposed extensive recordkeeping requirements

on the retailers’ wholesale suppliers and required Indian

retailers to collect a cigarette excise tax from non-Indian

purchasers. The law was enacted to prevent Indian

retailers from offering their own exemption from state

taxation to non-Indian cigarette purchasers. Because the

"legal incidence of the tax is on the . . . non-Indian buyer,"

Colville, 447 U.S. at 141-42, the Court found that the

wholesaler/Indian retailer relationship was not

impermissibly interfered with by the regulations. The Court

specifically considered the impact of the Indian trader laws

and rejected the preemption argument relied upon by the

New York Court of Appeals:

We do not believe that principles of federal

Indian law, whether stated in terms of pre-

emption, tribal self-government, or otherwise,

authorize Indian tribes to market an

exemption from state taxation to persons who

would normally do their business elsewhere.

Id. at 155. The Court went on to authorize the State to

regulate the actions of the Indian retailers’ wholesale

suppliers by requiring the suppliers to keep detailed records

regarding their taxable and nontaxable sales to Indian

retailers. /d. at 160. Moreover, the Court even went so far

~

as to permit the State to seize untaxed cigarettes in transit

from wholesalers if the Indian retailers refused to

cooperate in the collection of State taxes. Jd. at 161-62.

There was not the slightest suggestion in this opinion that

the Indian trader laws preempted these regulatory

requirements.

In Potawatomi, the Court further solidified the

principle that states may require Indian wholesale suppliers

to assist in collecting valid state taxes. In that case, the

State of Oklahoma sought to impose an assessment for $2.7

million in back taxes on cigarette sales against a

convenience store owned and operated by the Potawatomi

Tribe. The Tribe claimed that its sovereign immunity

prevented the State from suing it directly to collect the

back taxes. While the Court agreed with this position, as

it did in Moe and Colville, the Court reaffirmed its earlier

holdings that Indian retailers were not exempt from

assisting the State with prospective tax collection:

"Although the doctrine of tribal sovereign immunity applies

to the Potawatomis, that doctrine does not excuse a tribe

from all obligations to assist in the collection of validly

imposed state sales taxes." Potawatomi, 498 U.S. at 512.

The Court specifically authorized states to require

wholesalers to assist in collecting these taxes:

And under today’s decision, States may of

course collect the sales tax from cigarette

wholesalers, either by seizing unstamped

cigarettes off the reservation, or by assessing

wholesalers who supplied unstamped cigarettes

to the tribal stores.

Id. at 514 (emphasis added; citations omitted).

2. The Court Of Appeals’ Decision Is

Wrong

The decision of the New York State Court of

Appeals is in direct conflict with Moe, Colville and

Potawatomi. The lower court relied upon this Court’s prior

decision in Warren Trading Co. for its conclusion that the

New York regulations are preempted by the federal Indian

trader laws. The Court of Appeals held that despite the

express language of Potawatomi permitting states to require

wholesalers to assist in the collection of taxes, such

language “did not alter the established rule stated in Warren

Trading Post v. Tax Commission that Congress has taken the

matter of regulating Indian trades so fully in hand...

because it cites none of the relevant decisions in this area."

Milhelm Attea & Bros., Inc. v. Department of Taxation, 615

N.E.2d 994, 1001 (N.Y. 1993). The Court of Appeals

totally ignored the fact that Warren involved a sales tax that

was levied directly on the Indian retailer. Here, the

ultimate burden of the tax is indisputably on the non-Indian

consumer. Moe, Colville, and Potawatomi authorize the

State to require Indian wholesalers to assist in the

collection of the excise taxes under these circumstances.

The lower court further held that this Court’s

statement in Potawatomi only meant that the "remedy" of

imposing a tax directly on wholesalers could only be

employed retroactively to collect unpaid taxes on past

cigarette sales. This distinction makes no sense. If the

Indian trader laws, or any federal law governing Indian

affairs, preempt states from exercising regulatory authority

over Indian traders in their dealings with Indian customers,

it is irrelevant that the state seeks to exercise its authority

prospectively or retrospectively. Amy exercise of authority

would be preempted. Because Potawatomi approves of the

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State’s right to collect taxes from Indian retailers by

requiring wholesale suppliers to assist in the process, the

Court of Appeals should be reversed.

B. The Regulations Impose Permissible

Minimal Burdens On Indian Traders

State regulations that require Indian retailers and

their wholesale suppliers to assist in the collection of valid

State taxes are permissible if they are not unreasonably

burdensome. Moe, 425 U.S. at 483; Colville, 495 U.S. at

159-60. In Moe, the Court characterized the requirement

that Indian retailers collect the tax as a "minimal burden

designed to avoid the likelihood that in its absence non-

Indians purchasing from the tribal seller will avoid payment

of a concededly lawful tax." Moe, 425 U.S. at 483. While

Moe did not discuss whether such a "minimal burden" could

be imposed on the Indians’ wholesale suppliers, a point

seized upon by the Court of Appeals, there is no reason to

make a distinction between retailers and wholesalers. In

Potawatomi, the Court authorized the imposition of burdens

on wholesalers supplying Indian retail outlets in order to

secure the collection of valid state cigarette taxes.

Potawatomi, 495 U.S. at 514. This is in contrast to the

Court of Appeals’ conclusion that every transaction

between an Indian tribe and its supplier may not be

regulated by the states.

Nonetheless, the Court of Appeals held that the

New York regulations impermissibly place "significant"

burdens on wholesalers. But the Court of Appeals gave no

justification for this extraordinary conclusion. The

challenged New York regulations, as applied to

wholesalers, are limited in scope: they merely require that

cigarette distributors making tax free sales of cigarettes to

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businesses located on Indian reservations keep accurate

records of their sales, keep a copy of the businesses’ tax

exemption certificates, and verify their sales to Indian

retailers by forwarding tax exemption coupons issued by the

State to the Department of Taxation and Finance. New

York Comp. Codes R. & Regs. tit. 20, § 335.6(f) and (g).

In contrast, the Colville Court approved much more

arduous recordkeeping requirements which mandated that

Indian retailers (1) record the number and dollar volume

of taxable sales to nonmembers of the tribe; (2) with

respect to nontaxable sales, record the names of all Indian

purchasers, their tribal affiliations, the reservations within

which the sales are made, and the dollar amount and dates

of the sales; and (3) review each Indian purchaser’s tribal

identification card unless the purchaser is personally known

to the retailer. Colville, 447 U.S. at 159-61.

The Court in Colville noted that the Indian retailers

failed to present any evidence as to whether the

requirements of the Washington law were overly

burdensome. The Court accordingly held that the tribes

failed to meet their burden of showing that the challenged

tax scheme was not reasonably necessary as a means to

prevent non-Indian consumers from evading taxes. /d. at

160. Likewise, the respondents in this case failed to

present any evidence on the issue of burden, or any

evidence showing that the regulations in issue were not

reasonably necessary to prevent similar tax evasion in New

York. Under these circumstances, the Court of Appeals

erroneously determined that the New York law overstepped

the boundaries of acceptable state regulation.

2.

Brit ces a

Cc. The New York Regulations Should Be

Upheld Because They Protect The Valid

Interests Of Amici And Other Non-Indian

Retail Businesses In Fair Competition

The New York regulations in question should be

upheld to prevent unfair competition between Indian and

non-Indian retailers selling cigarettes and other consumer

goods. As previously mentioned, Indian retailers

historically have refused to collect valid state taxes on sales

of cigarettes to non-Indian purchasers.” This is done

intentionally to enable Indian retailers to market their

exemption from state taxes to non-Indian purchasers, who

enjoy no such exemption, and sell cigarettes at unnaturally

low prices. Both Moe and Colville recognized that Indian

retailers selling untaxed cigarettes to non-Indian consumers

realize an artificial competitive advantage over non-Indian

retailers who are required to collect the tax. See Moe, 425

U.S. at 482; Colville, 447 U.S. at 154-56. However, the

Court in Colville specifically stated that such actions are

prohibited: "None of the federal laws concerned with

fostering tribal economic development goes so far as to

grant tribal enterprises selling goods to nonmembers an

artificial competitive advantage over all other businesses in

a State.” Colville, 447 U.S. at 155.

The failure of Indian retailers to collect taxes on

cigarette sales to non-Indians prevents non-Indian retailers

with businesses near the reservation from effectively

competing for such sales. Because Amici’s members collect

3/ Indian tribes often attempt to justify these actions by

referring to their need to foster economic development and

generate revenue for "essential governmental programs."

Colville, 447 U.S. at 154.

«it.

all applicable State taxes on cigarettes, they simply cannot

match the Indian retailers’ bargain prices. These discount

sales by Indian retailers to non-Indians deprive the retailers

in New York and across the country of millions of dollars

annually in cigarette sales that they might make but for the

Indian retailers’ artificially low prices.” The New York

regulations would compel Indian retailers to collect the

State tax on cigarette sales to non-Indians, and thereby

prevent the retailers from "marketing" their tax exemption

to non-Indian consumers who would normally purchase

cigarettes elsewhere.

The artificially low prices offered by Indian retailers

also deprive retailers of the ancillary revenue generated by

the sales of products non-Indian consumers purchase at the

same time they buy cigarettes. Data indicates that cigarette

smokers purchase cigarettes from convenience stores

approximately three times per week. Moreover, these

purchasers make more than three times the number of trips

to convenience stores per week than do non-smokers. As

a result of the stores’ geographic convenience and

purchasing ease, these consumers also tend to spend

additional money on soft drinks, newspapers, magazines,

coffee and bakery items each time they purchase cigarettes.

By offering cigarettes to non-Indian consumers at bargain

prices, Indian retailers wrongly divert customers away from

convenience stores which do comply with the law. This

results in a dramatic decrease in the volume of sales for the

non-Indian retailers. In some cases, retailers who operate

convenience stores near retail outlets on Indian

4/ Recent decisions by supermarkets, drugstores and other

retail entities to decrease their sales of tobacco products

mean that convenience stores are often a consumer’s only

source for cigarettes.

» Me

reservations have closed their stores due to their low

volume of business.

In sum, Congress never intended for Indian retailers

to reap the windfalls that arise from their repeated sales of

untaxed cigarettes to non-Indian purchasers. This Court

should not perpetuate this unfairness by voiding New

York’s appropriate procedures to collect its taxes.

CONCLUSION

For the foregoing reasons, the Amici urge this Court

to reverse the decision of the New York State Court of

Appeals and affirm the constitutionality of the New York

regulations in question.

Respectfully submitted,

MARK L. AUSTRIAN

(Counsel of Record)

JASON M. BRANCIFORTE

Collier, Shannon, Rill & Scott

3050 K Street, N.W., Suite 400

Washington, D.C. 20007

(202) 342-8400

Counsel for Amici Curiae

National Association of

Convenience Stores, New York

Association of Convenience

Stores, Independent Petroleum

Marketers Of New York, Inc.

and Society Of Independent

Gasoline Marketers Of America

Dated: December 16, 1993

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APPENDIX

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APPENDIX

Arizona Petroleum Marketers Association

Arkansas Grocers & Retail Merchants Association

Georgia Oilmen’s Association

Minnesota Service Station Association

Missouri Petroleum Marketers Association/

Missouri Association of Convenience Stores

Montana Petroleum Marketers Association

New England Convenience Store Association

New Mexico Petroleum Marketers Association

North Dakota Petroleum Marketers Association

Retail Grocers Association of Arizona

Retail Grocers Association of Florida

Washington Oil Marketers Association