Legal Opinion

State ex rel. Arizona Department of Revenue v. Talley Industries, Inc.

Court of Appeals of Arizona

Decided September 13, 1994No. 1 CA-TX 92-0013PublishedCited by 16 opinions

1Opinion of the Court

OPINION

TOCI, Judge.

This appeal involves the Arizona income of Talley Industries, Inc. (“Talley”) and its twenty-five subsidiary companies (collectively, “the Talley group”). In 1983, Talley apportioned 16.26 percent of the combined net income of the Talley group for Arizona state income taxation.1 Talley contends that the Talley group is a “unitary business” and thus is entitled to apportion to Arizona a share of the Talley group’s overall income from sources within and outside Arizona. The Arizona Department of Revenue (“the Department”) argues that this Arizona apportionment ratio does not…

2Cases cited15 opinions

  1. Container Corp. of America v. Franchise Tax BoardSupreme Court of the United States · 1983
  2. Underwood Typewriter Co. v. ChamberlainSupreme Court of the United States · 1920
  3. Earth Resources Co. of Alaska v. State, Department of RevenueAlaska Supreme Court · 1983
  4. Commonwealth v. ACF Industries, Inc.Supreme Court of Pennsylvania · 1970
  5. Snoddy v. McNairSupreme Court of the United States · 1970

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3Cited by16 opinions

  1. Barlage v. ValentineCourt of Appeals of Arizona · 2005
  2. Louis Dreyfus Corp. v. HuddlestonCourt of Appeals of Tennessee · 1996
  3. Tesoro Corp. v. State, Department of RevenueCourt of Appeals of Alaska · 2013
  4. Arizona Department of Revenue v. Central Newspapers, Inc.Court of Appeals of Arizona · 2009
  5. M.D.C. Holdings, Inc. v. State Ex Rel. Arizona Department of RevenueCourt of Appeals of Arizona · 2009

11 more not listed; retrieve them via the Exa API.

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