Vodafone Americas Inc. v. Indiana Department of State Revenue

ORDER ON PETITIONERS’ MOTION FOR SUMMARY JUDGMENT

FISHER, Senior Judge.

Vodafone Americas Inc. and Vodafone Holdings LLC (collectively, Vodafone) appeal the two final determinations of the Indiana Department of State Revenue denying their claims for refund of adjusted gross income tax paid during the taxable years ending March 31, 2005 through March 31, 2008 (the years at issue). The appeal is currently before the Court on Vodafone’s motion for summary judgment (Motion). In its Motion, Vodafone asks the Court to answer one question: whether the income it received as a partner of a general…