Texaco, Inc. v. Wasson

Rhodes, Justice.

The appellant (Texaco, Inc.) brought this action to recover $249,024 in South Carolina income taxes and interest (paid under protest) assessed against it by respondent (South Carolina Tax Commission) for the years 1970, 1971 and 1972. It appeals from a circuit court decree upholding the assessment and dismissing the action. We affirm as to the assessment of taxes but reverse as to interest.

Texaco operates a multi-state, unitary business, a portion of which business is conducted in South Carolina. From 1934 until 1969, Texaco paid taxes to this state under the apportionment…