Agilent Techs., Inc. v. Dep't of Revenue of State

Opinion by JUDGE BOORAS

¶ 1 In this taxpayer dispute, we resolve whether a corporation with no property or payroll of its own must be included in a *941Colorado combined income tax return. Plaintiff, Agilent Technologies, Inc. (Agilent), and defendants, the Department of Revenue of the State of Colorado (Department) and Barbara Brohl, in her official capacity as the Executive Director of the Department (Director), appeal the district court's entry of summary judgment in Agilent's favor. The district court concluded that Agilent was not required to include its holding company, Agilent Technologies…