Uniroyal Tire Co. v. State Department of Revenue

BEATTY, Retired Justice.

Uniroyal Tire Company, Inc. (“Uniroyal”), appeals from a circuit court order determining a tax liability against it. We affirm.

The State Department of Revenue (“Department”) assessed corporate income tax against Uniroyal for the tax year 1990, following Uniroyal’s sale of a partnership interest. The assessment came about from the following facts.

In 1986, Uniroyal entered into a partnership with the B.F. Goodrich Company, wherein both corporations transferred their assets to the partnership and each received a 50% partnership interest. Thereafter, Uniroyal’s only asset…