Legal Opinion
Allied-Signal Inc. v. Commissioner of Finance
New York Court of Appeals
Decided December 23, 1991PublishedCited by 9 opinions
1Opinion of the Court
OPINION OF THE COURT
Titone, J.
In this appeal we are called upon to determine whether New York City may constitutionally tax any portion of the dividend and capital gain income that a nondomiciliary corporation receives by reason of its investment in another corporation conducting business within the City in the absence of a unitary business relationship between the two *76corporations.1 For the reasons that follow, we conclude that the City may do so without offending either the Due Process Clause (US Const 14th Amend) or the Commerce Clause (US Const, art I, § 8) of the Federal Constitution.
I.…
2Cases cited20 opinions
- Complete Auto Transit, Inc. v. BradySupreme Court of the United States · 1977
- Wisconsin v. J. C. Penney Co.Supreme Court of the United States · 1941
- Container Corp. of America v. Franchise Tax BoardSupreme Court of the United States · 1983
- Shaffer v. CarterSupreme Court of the United States · 1920
- Mobil Oil Corp. v. Commissioner of Taxes of Vt.Supreme Court of the United States · 1980
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3Cited by9 opinions
- Bridges v. Autozone Properties, Inc.Supreme Court of Louisiana · 2005
- Corrigan v. Testa (Slip Opinion)Ohio Supreme Court · 2016
- Allied-Signal Inc. v. Tax Appeals Tribunal of the Department of Taxation & FinanceAppellate Division of the Supreme Court of the State of New York · 1996
- Lowit v. Consolidated Edison Co. of New York, Inc.Appellate Division of the Supreme Court of the State of New York · 1996
- Cable & Wireless, Inc. v. City of New York Department of FinanceNew York Supreme Court · 2001
4 more not listed; retrieve them via the Exa API.