Alabama Department of Revenue v. Jim Beam Brands Co.

MOORE, Judge.

This is a corporate-income-tax case. The facts are undisputed. Jim Beam Brands Company, Inc., is a multistate corporation doing business in Alabama. Jim Beam filed amended Alabama corporate tax returns for the 1993 and 1994 tax years. In those amended returns, Jim Beam claimed additional interest-expense deductions attributable to its Alabama business activities. After auditing those amended returns, the Alabama Department of Revenue (“the Department”) disallowed the interest-expense deductions claimed by Jim Beam, asserting that Jim Beam had incorrectly apportioned its…