Cooper Industries, Inc. v. Indiana Department of State Revenue

FISHER, Judge.

Petitioners are a group of corporations operating as a unitary business. In 1988, the common parent of the group filed its federal income tax return on a consolidated basis. For purposes of Indiana income taxes, however, the parent and those member corporations with ties to Indiana used the combined reporting method. Also in 1988, the parent sold two subsidiaries and, as required by federal regulations, included the “excess loss account” income associated with those entities in its federal consolidated taxable income. Inasmuch as Indiana income taxes begin with the taxpayer’s…