L. J. Minor Corp. v. Breitenbach

The issue before this court is whether Minor was required to pay municipal income taxes to the city of Cleveland on sales resulting from purchase orders received in Cleveland from customers located outside Cleveland when the products that filled those orders were shipped to the customers from inventory stored in Brecksville.

The portion of a company’s net profits subject to a particular municipal corporation’s income tax is calculated by utilizing an apportionment formula that compares the company’s property, payroll, and sales within the boundaries of that municipal corporation to the…