Carmax Auto Superstores West Coast, Inc. v. South Carolina Department of Revenue

This appeal arises out of CarMax Auto Superstores West Coast, Inc.’s (CarMax West) protest of an assessment of corporate income taxes by the South Carolina Department of Revenue (the Department). CarMax West alleges the Administrative Law Court (ALC) erred in: (1) failing to place the burden of proof on the Department to establish by clear and convincing evidence that the standard statutory apportionment method used by CarMax West does not reflect the extent of CarMax West’s business in South Carolina and that the Department’s alternative accounting method is reasonable; (2) failing to…