American Telephone & Telegraph Co. v. State Tax Appeal Board

In this case we hold principally that where corporate taxpayers are engaged in a unitary business, sales by the corporations of temporary cash investments are not to be reported by them for Montana’s corporation license tax or income tax purposes as included in gross sales; and, except for the net gain from such sales, the total amounts of such sales should be excluded from the formula determining the unitary businesses’ income for Montana Corporation License Tax reporting.

The taxpayers here are American Telephone and Telegraph Company (AT&T), AT&T Technologies (Technologies), formerly known…