Polaroid Corp. v. Commissioner of Revenue

Polaroid Corporation (Polaroid) and its subsidiaries have conducted a unitary business in the United States and in numerous foreign countries for the purpose of the design, manufacture, and marketing of a variety of products, primarily in the field of photography. Well after the plaintiffs had filed their corporate excise returns for the years 1979 and 1980, the Commissioner of Revenue (commissioner) 2 redetermined their corporate excises for those years based on a worldwide unitary apportionment of the combined income of Polaroid and its various subsidiaries. In September, 1983, he made…