NCR Corp. v. South Carolina Tax Commission

Toal, Justice:

This appeal involves an attempt by NCR Corporation (“NCR”) to recover certain corporate income taxes and li cense fees paid under protest to the South Carolina Tax Commission (“Tax Commission”). The trial judge ruled that no refund should be given NCR. We affirm in part and remand.

FACTS

NCR is a multinational corporation engaged in the business of developing, manufacturing, marketing, installing, and servicing business information processing systems. All phases of NCR’s businesses are conducted partly within and partly without South Carolina. In foreign countries, NCR conducts…