Westinghouse Electric Corp. v. Porterfield

Appellee, Westinghouse Electric Corporation, in filing its franchise tax returns for each of the years 1960 to 1964, inclusive, allocated only its sales of goods and services to the “business done” fraction provided by R. C. 5733.05, and paid its corporate franchise taxes accordingly.

On June 7, 1966, Westinghouse filed applications for refund for each of those tax years, claiming that annual dividends, interest, rents and royalties received by it, as well as its annual gross receipts from sales and dispositions of tangible property (other than goods manufactured by it) *51and of securities owned…