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OCR: 18 tices The Unitcd States firmly concluded, both at the certiorari stage put on the merits ir this case that "Sub section {b}(4} prohibits tax discrimination against rail carriers any form and 11 any imcthod including through exemptions at other business property United States BT 12-13 see also ("under Subsection {b}{4} the States are precluded froni employing prop erty tax excmptions Ir manner that results in discrim ination against rail carriers); United States petition stare) ("Yproperty tax] exemptions are properly to be considered in determining whether the State has. by this other tax effected discrimination against rail carriers") Likewise, every court of appeals to have addressed the question has held, likc Ninth Circuit this case Pet. App. 9a-16a, that subsection {b}{4} catch-all ...