House of Seagram, Inc. v. Porterfield

The basic issue in this case concerns the interpretation of that portion of R. C. 5733.05 which provides the guidelines for measuring the business done fraction of the Ohio franchise tax of a foreign corporation en*99gaged in sales of tangible personal property. The salient language of R. 0. 573'3.Q5 reads, in part:

“* * * (I) To the extent that the value of business done in this state is measured by sales of tangible personal property, it shall, for the purpose of this section and of Section 5733.03 of the Revised Code, mean sales where such property is received in this state by the purchaser.…