Texaco-Cities Service Pipeline Co. v. McGaw

Plaintiff, Texaco-Cities Service Pipeline (Texaco-Cities), brought an action for administrative review in the circuit court of Cook County against defendant, the acting director of the Illinois Department of Revenue (Department). Texaco-Cities sought review of the Department’s determination that (1) proceeds from the sale of a pipeline and associated assets constituted “business income” under the Illinois Income Tax Act (Act) (35 ILCS 5/101 et seq. (West 1994)), and (2) the income was apportionable under the single-factor, “barrel miles” formula of section 304(d)(2) of the Act (35 ILCS…