Sun Finance & Loan Co. v. Kosydar

The sole issue before this court is whether, the business done by Sun’s out-of-state consumer finance subsidiaries, which subsidiaries do not operate offices in Ohio, should be included in the R. C. 5725.15 apportionment formula utilized to determine the extent to which Sun’s total net worth is to be allocated to Ohio.1

There is no question that Sun is a “dealer in intangibles” as that term is defined in R. C. 5725.01 (B).2 As *285such, Sun is admittedly subject to the Ohio dealer-in-intangibles tax. The question presented, then, is to what ex:tent is Sun so subjected.

Resolution of the issue…