British Land (Maryland), Inc. v. Tax Appeals Tribunal
New York Court of Appeals
1Opinion of the Court
OPINION OF THE COURT
Levine, J.
The issue on this appeal is whether the State violated the Due Process and Commerce Clauses of the United States Constitution by assessing a corporation franchise tax (see, Tax Law art 9-A) on about 64% of petitioner’s gain from its sale of commercial real property in Baltimore, Maryland, in 1984.
According to the essentially uncontested evidence and as found by the State Tax Appeals Tribunal, petitioner was incorporated in Delaware in May 1973. Petitioner was an indirect, six times removed subsidiary of British Land Company Pic., an international real estate…
2Cases cited10 opinions
- Container Corp. of America v. Franchise Tax BoardSupreme Court of the United States · 1983
- Mobil Oil Corp. v. Commissioner of Taxes of Vt.Supreme Court of the United States · 1980
- Hans Rees' Sons, Inc. v. North Carolina Ex Rel. MaxwellSupreme Court of the United States · 1931
- Butler Bros. v. McColgan, Franchise Tax CommissionerSupreme Court of the United States · 1942
- Underwood Typewriter Co. v. ChamberlainSupreme Court of the United States · 1920
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