Johns-Manville Products Corp. v. Commissioner of Revenue Administration

This is an appeal under RSA ch. 541 from the decision of the board of taxation (board) to include in plaintiff’s business profits tax liability (RSA ch. 77-A) an allocable portion of the gain from the sale of timberland in Natchez, Mississippi.

Plaintiff is a Delware corporation with places of business in New Hampshire, Mississippi and fourteen other States. It is engaged primarily in the manufacture of pipe, diatomite, insulations and *429various industrial specialities. It operates manufacturing facilities in Nashua and Tilton, New Hampshire.

In 1946, it acquired about 36,000 acres of land in…