Commonwealth v. Olin Corp.

Olin Corporation is a Virginia corporation having income that is taxable both within and without this State. The Virginia income tax law permits such a corporation to apportion its income according to a formula that takes into account the percentages of total property, payroll, and sales within this. State. Code § 58-131.2.

*54In its State income tax returns for 1963 and 1964, Olin computed its net taxable income as follows: Olin (1) subtracted from gross income all deductions except accelerated amortization of a water pollution control facility in this State, (2) multiplied the difference by the…