Alabama Department of Revenue v. Kimberly-Clark Corp.

PITTMAN, Judge.

This appeal and this petition for a writ of mandamus arise out of a dispute that *822has engendered more than 10 years of litigation between the Alabama Department of Revenue (“the Department”) and Kimberly-Clark Corporation (“KC”) and its subsidiary, Kimberly-Clark Worldwide, Inc. (“KCW”). The dispute— whether the gain derived from the sale by KC of a pulp-and-paper-manufacturing facility in Alabama known as the Coosa Mill and the sale by KCW of 375,000 acres of adjacent timberland known as the Coosa Timberlands should be classified as “business income” or “nonbusiness income” for…