Does the Commission acting under an advisory compact with no ability to bind the states have governmental immunity? If the Commission is acting under a model law, why would there be any immunity? Could one state be held liable for the actions of its agent involving another state? On tax practitioner has said that "[A]s an initial matter, because the commission has argued in so many different forums that the compact is essentially a model law and not an agreement of sovereigns, I think it is going to be difficult to argue that the commission is a state actor and by its mere existence entitled to be covered by the blanket of state sovereign immunity. That means suing the commission is not tantamount to suing the state; traditional rules applicable to third-party agents of the states would seem to apply to acts of commission employees."