Alabama Department of Revenue v. Sonat, Inc.

ROBERTSON, Presiding Judge.

The Alabama Department of Revenue (“the Department”) appeals from a judgment in favor of Sonat, Inc., ordering the Department to set aside its final 1988 corporate income tax assessment against So-nat and to refund $12,163,702.00 plus interest in corporate income tax collected from Sonat as a result of the assessment. We reverse.

This appeal involves the interpretation of § 40-18-35, Ala.Code 1975, which specifies several items that are deductible from a corporation’s income when computing its income tax liability. Among these items is a deduction for dividends…