Dep't of Revenue v. Agilent Techs., Inc.

JUSTICE GABRIEL delivered the Opinion of the Court.

¶1 This case principally requires us to decide two questions. First, we must determine whether the Colorado Department of Revenue and Michael Hartman, in his official capacity as the Executive Director of the Department (the "Director" and collectively with the Department, the "Department"), can require Agilent Technologies, Inc. ("Agilent") to include its holding company, Agilent Technologies World Trade, Inc. ("World Trade"), in its Colorado combined income tax returns for the tax years 2000-07. Second, if the answer to that question is no,…