Legal Opinion

In re the Income Tax Protest of Williams Natural Gas Co.

Supreme Court of Oklahoma

Decided June 9, 1992No. 77064PublishedCited by 3 opinions

1Opinion of the Court

HODGES, Vice Chief Justice.

The dispositive issue in this appeal is which of two statutory methods applies to calculate the sales factor for apportioning income to Oklahoma from a unitary, multi-state, corporate business. A subsidiary issue is whether the taxpayer is entitled to costs and attorney fees for challenging the Oklahoma Tax Commission’s choice of method for calculating the sales factor.

Williams Natural Gas Company (WNG), is a wholly-owned subsidiary of The Williams Companies, Inc. It is a unitary, multistate business which purchased and marketed natural gas in a seven-state area.…

2Cases cited4 opinions

  1. Mothershed v. MothershedSupreme Court of Oklahoma · 1985
  2. Replogle v. Indian Territory Illuminating Oil Co.Supreme Court of Oklahoma · 1943
  3. Thornton v. WoodsonSupreme Court of Oklahoma · 1977
  4. Internorth, Inc. v. Iowa State Board of Tax ReviewSupreme Court of Iowa · 1983

3Cited by3 opinions

  1. State Ex Rel. State Insurance Fund v. Great Plains Care Center, Inc.Supreme Court of Oklahoma · 2003
  2. WAREHOUSE MARKET v. STATE ex rel. OKLAHOMA TAX COMM.Supreme Court of Oklahoma · 2021
  3. WAREHOUSE MARKET v. STATE ex rel. OKLAHOMA TAX COMM.Supreme Court of Oklahoma · 2021

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