Legal Opinion
Albertson's, Inc. v. State, Dept. of Revenue
Idaho Supreme Court
Decided May 23, 1984No. 14808PublishedCited by 9 opinions
1Opinion of the Court
HUNTLEY, Justice.
The principal issue on appeal is whether it is appropriate to treat the income of a Texas corporation which is a wholly-owned subsidiary of Albertson’s, Inc. as income of the parent corporation, subject to apportionment under the Idaho version of the Uniform Division of Income for Tax Purposes Act (UDITPA). Fundamental to the determination of that issue is whether the two corporations constitute a “unitary business” for tax purposes.
I
THE FACTUAL BACKGROUND
In 1965 Idaho adopted with slight modification the Uniform Division of Income for Tax Purposes Act (UDITPA). I.C. §…
2Cases cited16 opinions
- Container Corp. of America v. Franchise Tax BoardSupreme Court of the United States · 1983
- Mobil Oil Corp. v. Commissioner of Taxes of Vt.Supreme Court of the United States · 1980
- Moorman Manufacturing Co. v. BairSupreme Court of the United States · 1978
- Butler Bros. v. McColgan, Franchise Tax CommissionerSupreme Court of the United States · 1942
- ASARCO Inc. v. Idaho State Tax CommissionSupreme Court of the United States · 1982
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3Cited by9 opinions
- Wachovia Bank of North Carolina, N.A. v. JohnsonCourt of Appeals of Tennessee · 2000
- AIA Services Corp. v. Idaho State Tax CommissionIdaho Supreme Court · 2001
- Parsons v. Idaho State Tax Commission, Department of Revenue & TaxationIdaho Court of Appeals · 1986
- David v. Idaho State Tax CommissionIdaho Supreme Court · 2010
- Cable One, Inc. v. Idaho State Tax CommissionIdaho Supreme Court · 2014
4 more not listed; retrieve them via the Exa API.