As promised during his State of the State address, Gov. Andrew Cuomo, D-NY, is moving forward with plans to sue the federal government over the recently enacted tax reform. During a conference call Friday, Cuomo announced a multi-state coalition that plans to take legal action.

The coalition currently includes New York, New Jersey, and Connecticut but the governors of  those states said they expect many of the other states negatively impacted by the new tax code to join over the next few days. The main qualm with the bill is the partial elimination of deductibility for state and local taxes.

Cuomo said there are a number of strong arguments the legislation is unconstitutional, pointing to states’ rights to tax, citizens’ rights not to be double taxed, and the Equal Protection Clause.

“The top 12 states that get hurt coincidentally all happen to be Democratic states, coincidentally have virtually no representation in the United States Senate, coincidentally only have a small minority of House members, coincidentally are states that President Trump lost in the last election,” Cuomo said.

The three governors said in the coming days they’ll work out where they’ll file the lawsuit but they expect it would be in one of their states because they’re affected the most. Gov. Dan Malloy, D-Connecticut, said he would expect the litigation to move quickly although noting the discovery process should be interesting.

“I can’t imagine that there aren’t Republican documents and communications between the likes of (Senate Majority Leader ) Mitch McConnell and the Speaker and so many others about what they were doing to those blue states.,” Malloy said.

Cuomo said the 12 states negatively affected together represent more than 40 percent of the country’s Gross Domestic Product. The governor at the same time is looking at state legislation like a payroll tax or state-run charitable fund to mitigate the deductibility issue.

Republican members of Congress have argued the partial elimination of the SALT deductible does not impact middle-class taxpayers because the standard deduction was doubled.