Nationwide Corp. v. Schneider

The tax overpayment which is claimed was payable upon the total value of the stock of the corporation issued and outstanding. Section 5733.05, Revised Code, requires the Tax Commissioner to divide that value into two equal parts. That section further requires the Tax Commissioner to determine the fraction which represents the ratio of the corporation’s property in Ohio to all its property wherever situated and to determine the fraction which represents the ratio of the corporation’s business done within this state to all its business wherever done. The Tax Commissioner is then required to…