Norrell Services, Inc. v. Indiana Department of State Revenue

ORDER ON PARTIES' CROSS MOTIONS FOR SUMMARY JUDGMENT

FISHER, J.

Norrell Services, Inc. (Norrell) appeals the Indiana Department of State Revenue's (Department) imposition of Indiana gross income tax on franchise fees Norrell received during the years ending November 1, 1992, October 31, 1998, and October 31, 1994 (the years at issue). The matter is currently before the Court on the parties' cross-motions for summary judgment.

FACTS AND PROCEDURAL HISTORY

The material facts as they relate to this case are undisputed. Norrell is a Georgia corporation with its principal office in Atlanta, Georgia.…