Gulf Oil Corp. v. Kosydar

The issue before the court, as it was before the Tax Commissioner and the Board of Tax Appeals, concerns construction of the “business done” apportionment formula contained in R. C. 5733.05 as it applied to tax years 1970 and 1971.

At that time, R. C. 5733.05 provided, in pertinent part:

“* * * j;ake tbe other part and multiply by a fraction whose numerator is the value of the business done, measured by sales of tangible personal property, by the corporation in this state during the year preceding the date of the commencement of its current annual accounting period, and whose denominator is the…