Oxford v. Nehi Corp.

Felton, Chief Judge.

The sole question for decision in this case is whether the out-of-state sales of a taxpayer who is engaged in the sale of tangible goods both within and without the state are taxable as Georgia income where the out-of-state deliveries are made under a contract that title to1 the goods passes to the purchaser at destination and where the three-factor formula provided for by Code (Ann.) § 92-3113 (4) (c) is applicable in determining the taxpayer’s tax by reason of the presence of all of the factors making the formula applicable, to wit: (a) the average inventory ration, (b)…