Dana Corp. v. Limbach

We hold that the BTA’s decision on the foreign income deductions was reasonable and lawful and, thus, affirm it. However, we hold that Dana failed to specify error concerning deducting property of financial institutions and insurance companies from its net worth property fraction in its notice of appeal filed with the BTA. Consequently, we reverse this aspect of the BTA’s decision.

I. Foreign Income Deduction

R.C. 5733.04(1) defines “net income” for the franchise tax as:

“* * * [T]he taxpayer’s taxable income before operating loss deduction and special deductions, as required to be reported for…