holding that liquidation of a partnership did not produce business income, but stating in dicta that "no significance is attached to the fact that a transaction involves a liquidation" under the functional test
How later courts described this case
- holding that liquidation of a partnership did not produce business income, but stating in dicta that "no significance is attached to the fact that a transaction involves a liquidation" under the functional test
- “[T]he 18 commercial domicile of a corporation is the place from which the business is managed or directed . . . .”
- considering where officers and employees worked, management meetings were held, books kept, and bank accounts located
- “The term, ‘commercial domicile,’ originated in the U.S. Supreme Court decision, Wheeling Steel Corp. v. Fox.”
Written by the judges who cited it.
The opinion
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ORDER ON PETITION FOR REHEARING
PER CURIAM.
The Appellee, Commissioner of Revenue of the State of Tennessee, has filed a petition for rehearing in this cause, which the Court has considered and concludes should be denied.
It is so ORDERED.