Tony W. Smith and Shirlena Smith v. Indiana Department of State Revenue

Tony W. Smith and Shirlena Smith have appealed, among other things, the Indiana Department of State Revenue's assessments of Indiana adjusted gross income tax (AGIT) for 2005 through 2007 and 2009 through 2014. The matter, currently before the Court on the Smiths' Motion for Partial Summary Judgment ("Motion"), presents the following issue of first impression: whether the Department's modifications to the Smiths' AGIT liabilities for 2005 through 2007 (the "years at issue") were limited to the modifications made by the Internal Revenue Service (the "IRS") to resolve the federal audit for…