Trawick Construction Co. v. Georgia Department of Revenue

CARLEY, Presiding Justice.

Prior to October 1, 1999, Trawick Construction Company, Inc. was a closely-held Florida corporation. For federal income tax purposes, Trawick was treated as a Subchapter S corporation. As a result, Trawick’s shareholders, instead of the corporation itself, were required to report their proportionate share of Trawick’s taxable business income on their individual tax returns and pay the appropriate federal income taxes. For Georgia state income tax purposes, however, Trawick was a Subchapter C corporation which paid taxes directly to the State of Georgia on business…