Legal Opinion
SFN Shareholders Grantor Trust v. Indiana Department of State Revenue
Indiana Tax Court
Decided November 13, 1992No. 49T10-9109-TA-00049PublishedCited by 8 opinions
1Opinion of the Court
FISHER, Judge.
Petitioner, SFN Shareholders Grantor Trust (SFN), the successor in interest to SFN Companies, Inc. (SFNCI), appeals the final determination by the Respondent, Indiana Department of State Revenue (the Department), assessing gross income tax on SFNCI's 1986 sale of shares in Scott, Foresman and Company (Scott Foresman). The case is before the court on SFN's motion for partial summary judgment.
ISSUE 1
Whether SFN's income from the sale of its Seott Foresman shares was derived from "sources within Indiana" within the meaning of IND.CODE 6-2.1-2-2(a)(2)?
FACTS
The parties do not dispute…
2Cases cited33 opinions
- United States v. Wallach, Rusty Kent London, Eugene Robert Wallach, A/K/A "E. Robert (Bob) Wallach," and Wayne Franklyn ChinnCourt of Appeals for the Second Circuit · 1991
- Olympia Equipment Leasing Company, Alfco Telecommunications Company, and Abraham Feldman v. Western Union Telegraph CompanyCourt of Appeals for the Seventh Circuit · 1986
- Rhode Island Hospital Trust Co. v. DoughtonSupreme Court of the United States · 1926
- Humphreys v. McKissockSupreme Court of the United States · 1891
- Burger Man, Inc. v. Jordan Paper Products, Inc.Indiana Court of Appeals · 1976
28 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Indiana Waste Systems of Indiana, Inc. v. Indiana Department of State RevenueIndiana Tax Court · 1994
- Global Credit Services, Inc. v. AMISUB (Saint Joseph Hospital), Inc.Nebraska Supreme Court · 1993
- Indiana Department of State Revenue v. Bethlehem Steel Corp.Indiana Supreme Court · 1994
- Knauf Fiber Glass, GmbH v. State Board of Tax CommissionersIndiana Tax Court · 1994
- Hayse v. Indiana Department of State RevenueIndiana Tax Court · 1994
3 more not listed; retrieve them via the Exa API.