dissenting.
The courts of appeals are better qualified to decide questions of state law than is this Court. Most circuit judges formerly practiced in States within their respective circuits. As judges, they must confront state-law issues on a regular basis. For these reasons, it has long been the settled practice in this Court to show the greatest deference to opinions of the courts of appeals on questions of state law. “In dealing with issues of state law that enter into judgments of federal courts, we are hesitant to overrule decisions by federal courts skilled in the law of particular states unless their conclusions are shown to be unreasonable.” Propper v. Clark, 337 U. S. 472, 486-487 (1949). See also Haring v. Prosise, 462 U. S. 306, 314, n. 8 (1983) (“a challenge to state-law determinations by the Court of Appeals will rarely constitute an appropriate subject of this Court’s review”); Leroy v. Great Western United Corp., 443 U. S. 173, 181, n. 11 (1979) (“it is not our practice to re-examine state-law determinations of this kind”); Bishop v. Wood, 426 U. S. 341, 345-347 (1976), and cases cited therein.
The outcome of this case depends entirely on an interpretation of the California Revenue and Taxation Code. I am not prepared to say that the Court of Appeals’ construction of the California Code is correct or incorrect.1 I am prepared, *14however, to disagree with the Court’s conclusion that we should undertake to decide the state-law question in a ease of this kind. Even if the Court is correct in its view that the Court of Appeals applied a mistaken standard in construing the California tax,2 that premise does not justify the action of the Court today in undertaking to decide the state-law issue on its own — particularly when that issue has not been fully briefed and argued. At most, the Court should remand the case to the Court of Appeals for a reconsideration under the proper standard. Such a remand would at least demonstrate that this Court has not forgotten that “federal judges who deal regularly with questions of state law in their respective districts and circuits are in a better position than we” to interpret state law. Butner v. United States, 440 U. S. 48, 58 (1979). Because the Court’s summary disposition conveys a different message, I respectfully dissent.
he Court of Appeals summarized its construction of the California statute as follows:
“Upon careful examination, it is apparent that section 30108(a) is merely a procedural section that denotes the manner in which a vendor shall collect a tax from a purchaser if and when the purchaser is obligated to pay the tax. In the case of a sale with respect to which ‘the [usual cigarette] tax imposed by Section 30101 is inapplicable,’ the vendor is required to collect the tax from the purchaser either (a) at the time of sale, if the purchaser is *14then obligated to pay the tax, or (b) if the purchaser is not then obligated to pay the tax, at the time the purchaser becomes so obligated. Cal. Rev. & Tax. Code § 30108(a) (West 1979). Collection by the vendor is mandatory, but only if and when the purchaser has a tax obligation. The section does not contain any substantive provisions that themselves impose any tax or that indicate when section 30101 is inapplicable. Nor does it specify under which situations a purchaser is obligated to pay the tax at the time of sale or, if the purchaser is not then obligated, when the purchaser becomes so obligated. We find no language in section 30108 — the only section on which the Board relies for its argument that the incidence of the tax falls upon the purchaser — that remotely suggests a legislative intent to have the purchaser pay the tax whenever the vendor is a non-taxable entity.” 757 F. 2d 1047, 1056-1057 (CA9 1985) (footnotes omitted).
The portion of the Court of Appeals opinion which I have quoted in n. 1, supra, suggests that the Court of Appeals would have reached the same conclusion even if it had not used the unfortunate word “explicit” earlier in its opinion.