Polaroid Corp. v. Offerman

SMITH, Judge.

Plaintiff Polaroid Corporation (“Polaroid”), domiciled in Massachusetts, filed this action seeking a partial tax refund pursuant to N.C. Gen. Stat. § 105-267 (1989) of income tax paid to the State of North Carolina for the 1991 tax year. Polaroid requests a refund of additional assessed taxes and interest totaling $499,177.00 based on a $924,526,554.00 recovery from a patent infringement suit Polaroid instigated in 1976 against Eastman Kodak Company (“Kodak”). See Polaroid Corp. v. Eastman Kodak Co., U.S.P.Q.2d 1711 (1991).

For North Carolina corporate income tax purposes,…