Consumer Direct, Inc. v. Limbach

We agree with the commissioner on both issues under appeal and reverse the decision of the BTA.

Former R.C. 5733.051(A)(2) and (8), for the pertinent years, provided:

“Net income of a corporation subject to the tax imposed by this chapter shall be allocated and apportioned to this state as follows:

“(2) Net rents and royalties from tangible personal property, to the extent such property is utilized in this state, are allocable to this state, if the taxpayer is otherwise subject to the tax provided by this chapter;

“(8) Any other net income, from sources other than those enumerated in subdivisions…