The use tax was created as a “counter-part” to the sales tax, and designed to capture tax revenue from sales made outside the state. As a result of the Supreme Court’s decision in Quill, the use tax is unenforceable since out-of-state sellers cannot be forced to collect that tax from in-state buyers. Even when use tax collection lines are placed on individual income tax returns, collections are paltry. The use tax has thus created a “nation of tax cheats.” In the name of simplicity and fairness, the use tax should be abolished.