In re Angle

The opinion of the court was delivered by

Miller, J.:

This is an appeal by the City of Eastborough from an order of the district court finding that certain intangibles belonging to the taxpayer, George A. Angle, had a business situs in the City of Wichita, and were thus not subject to the intangibles tax of the City of Eastborough for the year 1981.

Mr. Angle resides in the City of Eastborough, a city of the third class, which is surrounded on all sides by the City of Wichita. During the tax year, Angle maintained an office in the Kansas State Bank building in Wichita, from where he directed his…