Legal Opinion
Overseas National Airways, Inc. v. State Tax Commission
Appellate Division of the Supreme Court of the State of New York
Decided January 20, 1983PublishedCited by 1 opinion
1Opinion of the Court
OPINION OF THE COURT
Mikoll, J.
Petitioner Overseas National Airways, Inc. (ONA), a Delaware corporation with corporate headquarters in New York, was engaged in the interstate and foreign air transport of passengers and cargo.1 None of its flights was made entirely within New York State. Petitioner was assessed franchise tax deficiencies for several years from 1968 through 1977 for taxes allegedly due under section 184 of the Tax Law. These deficiencies are imposed as a result of various transactions in which ONA was involved and which took place in Europe and in States other than New York.
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2Cases cited9 opinions
- Mobil Oil Corp. v. Commissioner of Taxes of Vt.Supreme Court of the United States · 1980
- Japan Line, Ltd. v. County of Los AngelesSupreme Court of the United States · 1979
- Wheeling Steel Corp. v. FoxSupreme Court of the United States · 1936
- Matter of Good Humor Corporation v. McGoldrickNew York Court of Appeals · 1943
- New York Ex Rel. Whitney v. GravesSupreme Court of the United States · 1937
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3Cited by1 opinion
- Telephone & Telegraph Co. v. State Tax CommissionAppellate Division of the Supreme Court of the State of New York · 1983