Linear Films v. State Ex Rel. Tax Com'n

OPINION

BAILEY, Judge:

Linear Films, Inc. and subsidiaries (Taxpayer) seek review of an order of the Oklahoma Tax Commission (OTC) denying Taxpayer’s application for a refund of corporate income taxes paid. In this appeal, Taxpayer asserts error by OTC in determining Taxpayer’s sales of personal property outside of Oklahoma should be included within the Oklahoma tax base, arguing Taxpayer was not doing business outside Oklahoma for purposes of the Oklahoma corporate income tax code.

Briefly, Taxpayer is an Oklahoma corporation. Taxpayer owns and operates two plants — one in Tulsa, the other in…