Scioto Insurance Co. v. Oklahoma Tax Commission

1 This case concerns the liability of Scio-to Insurance Company, a Vermont corpora*783tion, for Oklahoma corporate income taxes for the years 2001 through 2005. The Oklahoma Tax Commission assessed Scioto corporate income taxes for these years based on payments it received from the use of Scioto's intellectual property by Wendy's restaurants in Oklahoma. The intellectual property in question consists of trademarks and operating practices for Wendy's restaurants.

T2 In support of its assessment, the Oklahoma Tax Commission points out that the amount of money Scioto receives for use of this…