construing allocation provision in corporate franchise tax to achieve the objective of taxing the fair value of Ohio business
How later courts described this case
- construing allocation provision in corporate franchise tax to achieve the objective of taxing the fair value of Ohio business
- using general statute-construing aids to construe allocation provision
Written by the judges who cited it.
The opinion
Holmes, J.,
dissenting. I must dissent in that, in my view, the Board of Tax Appeals reasonably found that the amounts involved here were received for technical services, and were derived from sources outside the United States, and as such were deductible from net income pursuant to R. C. 5733.04(I)(2).
I would affirm the order of the Board of Tax Appeals.
Hofstetter, J., concurs in the foregoing dissenting opinion.