Utica Bankshares Corp. v. Oklahoma Tax Commission

ALMA WILSON, Justice.

The dispositive issue is whether the Oklahoma Income Tax Act, §§ 2352, et seq., of Title 68 authorizes a deduction based on federal net operating loss over and above the federal net operating loss deduction allowed by the Internal Revenue Service for the corresponding tax year. We also decide whether 68 O.S.1981, § 2358(A)(3)(a) operates to allocate an Oklahoma carryback deduction where Oklahoma net operating loss is less than federal net operating loss and all federal losses are from Oklahoma sources. We also conclude that purely intra-state net operating loss deductions…