Illinois Tool Works, Inc. v. Lindley

Two issues are involved in this appeal. First, whether the value of property owned by the taxpayer and rented to a lessee which uses the property in its trade or business must be included in the computation of the taxpayer’s property factor pursuant to R. C. 5733.05(B)(2)(a). Second, whether the sale of treasury bills purchased at discount and subsequently sold at par value must be included in the computation of the sales factor pursuant to R. C. 5733.05 (B)(2)(c).

I

The formula for computing the property factor is set forth in R. C. 5733.05(B)(2)(a), which provides in relevant part:

“The…