tax returns who do not file are subject to penalties. Persons who fail to properly pay sales and use tax when due are also subject to penalties. The penalties tend to be based on the amount of tax not paid, and vary by jurisdiction. Tax audits All states imposing sales taxes examine sales and use tax returns of many taxpayers each year. Upon such audit, the state may propose adjustment of the amount of tax due. Taxpayers have certain rights of appeal, which vary by jurisdiction. Some states require payment of tax prior to judicial appeal, and some states consider payment of tax an admission of the tax liability. Constitutional limitations Under two now-overturned Supreme Court decisions, Quill Corp. v. North Dakota (1992) and National Bellas Hess v. Illinois (1967), states were not allowed to charge sales tax on sellers who did not have a physical presence or "nexus" in the state, such as companies doing mail order, online shopping, and home shopping by phone. Some states do attempt to charge consumers an identical per-transaction use tax instead, but compliance is relatively low due to the difficulty of enforcement. The June 2018 decision South Dakota v. Wayfair reversed this interpretation of the Commerce Clause, allowing states to collect sales tax from out-of-state merchants when the consumer is in the state. Several state constitutions impose limitations on sales tax. These limitations restrict or prohibit the taxing of certain items, such as food. By jurisdiction Sales tax rates and what is taxed vary by jurisdiction. The following table compares taxes on selected classes of goods in the states. Significant other differences apply. Following the table is abbreviated coverage of selected sales tax rates by state. Summary table Notes: These states tax food but give an income tax credit to compensate poor households: Hawaii, Idaho, Kansas, Oklahoma, South Dakota, and Wyoming. Uniform local taxes are included in the base rate in California & Utah (1.25%), and Virginia (1.0%). Alabama Alabama has a state general sales tax of 4%, plus any additional local city and county taxes. , the highest total general sales tax rate in Alabama is in the portions of Arab that are in Cullman County, which total to 13.5%. Alabama is one of the last three states to still tax groceries at the full state sales tax rate, which disproportionately affects minorities and low income families with children. City Tax Rates