Mississippi Department of Revenue v. AT & T Corp.

RANDOLPH, Justice,

for the Court:

¶ 1. In 1993, AT & T Corporation1 and affiliate corporations (collectively, “AT & T”) filed an affiliated group, Mississippi income tax return with the Mississippi Department of Revenue fik/a Mississippi State Tax Commission (“Commission”), using the statutorily-permissible “combined method” of reporting. See Miss.Code Ann. § 27-7-37(2)(a)(ii) (amended by Laws of 2004, eh. 371, § 1, effective January 1, 2004). But from 1994 to 1996, AT & T filed its returns under the “consolidated method” of reporting, which was then statutorily available only to affiliated…