Ashland Oil, Inc. v. Caryl

Appellant Ashland Oil, Inc., a Kentucky corporation, is an integrated oil company that maintains business locations worldwide, including in West Virginia. During the years at issue here, West Virginia imposed a gross receipts tax on persons selling tangible property at wholesale. W. Va. Code § ll-13-2c (1983). Local manufacturers were exempt from the tax. §11-13-2. The West Virginia Tax Department conducted a detailed audit of Ashland’s tax returns for fiscal years ending September 1975 and 1976 and assessed a deficiency in tax payments of $181,313.22 for wholesale sales with West Virginia…