Legal Opinion

Geoffrey, Inc. v. Oklahoma Tax Commission

Court of Civil Appeals of Oklahoma

Decided April 12, 2006No. 99,938PublishedCited by 6 opinions

1Opinion of the Court

OPINION

ADAMS, Presiding Judge.

¶ 1 Geoffrey, Inc. (Geoffrey), a Delaware corporation, appeals an Order of the Oklahoma Tax Commission (OTC) imposing corporate income tax on royalties Geoffrey received from the licensing of its intangible personal property during the years at issue, 1.e., 1992, 1993 and 1994 (tax years). Geoffrey argues such action violates the Commerce Clause 1 and the Due Process Clause 2 of the United States Constitution. We disagree and affirm the order.

STANDARD OF REVIEW

¶ 2 The appellate courts will review the entire record made before an administrative agency acting in…

2Cases cited21 opinions

  1. Complete Auto Transit, Inc. v. BradySupreme Court of the United States · 1977
  2. Quill Corp. v. North Dakota Ex Rel. HeitkampSupreme Court of the United States · 1992
  3. Container Corp. of America v. Franchise Tax BoardSupreme Court of the United States · 1983
  4. National Bellas Hess, Inc. v. Department of RevenueSupreme Court of the United States · 1967
  5. Allied-Signal, Inc. Ex Rel. Bendix Corp. v. Director, Division of TaxationSupreme Court of the United States · 1992

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3Cited by6 opinions

  1. Geoffrey, Inc. v. Commissioner of RevenueMassachusetts Supreme Judicial Court · 2009
  2. BRIDGES, SEC. OF DEPT. OF REV. v. GeoffreyLouisiana Court of Appeal · 2008
  3. AIG Insurance Management Services, Inc. v. Vermont Department of TaxesSupreme Court of Vermont · 2015
  4. MBNA America Bank, N.A. & Affiliates v. Indiana Department of State RevenueIndiana Tax Court · 2008
  5. Scioto Insurance Co. v. Oklahoma Tax CommissionSupreme Court of Oklahoma · 2012

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