People ex rel. Durand-Ruel v. Wells

I am of the opinion that the relators are continuously and permanently doing business in this State and that they are therefore taxable as for capital invested in this State on the amount of merchandise on hand. The question of permanency and continuity is primarily one of intent. Each cas'e must be considered on its own facts, and a circumstance quite determinative of intent *145m one case may prove secondary in another. If these cases presented simply the bald question of merchandise sent into this jurisdiction for sale this decision would probably have to be controlled by such" cases as People…