Park 100 Development Co. v. Indiana Department of State Revenue

HUNTER, Justice.

This cause is before us upon the petition to transfer of defendant-appellee, the Indiana Department of State Revenue (Department). The Court of Appeals, First District, reversed a lower court judgment which had affirmed an assessment of a corporation tax liability against Park 100. Park 100 Development Co. v. Indiana Department of State Revenue, (1979) Ind. App., 388 N.E.2d 293. We now grant transfer and vacate the opinion of the Court of Appeals. The judgment of the trial court is affirmed.

The evidence was summarized by the Court of Appeals as follows:

“Plaintiff-appellant…