Pancake House, Inc. v. Lindley

In calculating the value of its issued and outstanding stock under the net income method, pursuant to R. C. 5733.05(B), the corporate taxpayer begins with its base income, which equals its federal taxable income adjusted by certain deductions not relevant here. Allocable income from the sources mentioned in R. C. 5733.051(A) is subtracted from this figure. The resultant amount is apportionable income, which is subjected to the taxpayer’s Ohio apportionment ratio, determined by the three-factor formula of R. C. 5733.05(B). The income apportioned to Ohio and the income allocated to Ohio are…