Cooper Tire & Rubber Co. v. Limbach

Cooper presents three arguments: (1) R.C. 5733.05(B)(2)(a) should be interpreted to permit apportioning this mobile tangible personal property and compensation for employees operating this property; (2) Cooper established, under R.C. 5733.05(B)(2)(d), that an alternative formula to allocate these property values would more fairly represent the extent of Cooper’s business in Ohio; and (3) the federal Commerce and Equal Protection Clauses *349require apportioning the mobile equipment and the compensation paid to truck drivers and pilots. The commissioner denies these claims and also asserts that…