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Current corporate income tax developments .


* Several states, including California and New Jersey, enacted legislation suspending NOL deductions.

* New Illinois legislation allows an annual irrevocable election to treat all noncompensation income as apportionable business income.

* The Missouri and Massachusetts Supreme Courts decided several cases involving royalty payments for use of trademarks transferred by a parent to DHCs.


During 2002, an overwhelming number of state statutes were added, deleted or modified; court cases were decided; regulations were proposed, issued and modified; and bulletins and rulings were issued, released and withdrawn. Because it is impractical to summarize all of these activities, this article focuses on some of the more interesting items in the following corporate income tax areas: nexus; tax base; business/nonbusiness income; trademark/tradename cases and determinations; apportionment formulas; filing methods/unitary groups and administration. It also includes several other significant state tax developments. The first four areas are covered in Part I; the remaining areas will be covered in Part II, in the April 2003 issue.


* District of Columbia

According to nexus guidance (1) recently posted on the Office of Tax and Revenue's web page, for a business to have franchise tax nexus, it must be engaged in a business activity (that is not "protected" by Public Law (P.L.) 86-272) within the District or have physical presence there.

* Florida

The state Department of Revenue (DOR) ruled (2) that a limited liability company (LLC) that checked-the-box to be taxed as a corporation has nexus for Florida corporate income tax purposes solely through the use of an independent contractor who provides maintenance services to in-state customers.

* Georgia

Effective for years after 2001, the Georgia DOR amended Regulation 560-7-7-.03 to provide that a corporation is considered to own property or do business in Georgia whenever it is a limited or general partner in a partnership that owns property or does business in the state.

* Illinois

The DOR amended nexus Regulation 86 Ill. Adm. Code 100.9720 to clarify that a nonresident person does not have nexus with the state merely because the apportionment and allocation rules would cause that person to have Illinois net income.

* Massachusetts

In Alcoa Building Products, Inc., (3) the Appellate Tax Board ruled that P.L. 86-272 protections do not apply to warranty-claims activities performed by in-state sales representatives if such activities serve an independent business function apart from the solicitation of sales.

* New Jersey

Sweeping corporate tax reform in the Business Tax Reform Act of 2002, A2501, P.L. 2002, c. 40 (7/02/02) (NJBTA), included expanding the reach of the corporate business tax to corporations deriving receipts from sources within New Jersey or engaging in contacts with the state.

* New York

A New York State administrative law judge (ALJ) ruled (4) that a natural gas vendor transferring title to natural gas in the state at the same time that custody of the gas was transferred from a Canadian pipeline to a New York pipeline was not carrying on its business in the state and, thus, was not subject to the Section 186 gross receipts franchise tax. The ALJ noted that the taxpayer's "very brief ownership of the gas and transfer of title in New York was not sufficient to establish even a `slightest presence' in New York."

In another situation, a company sent individuals into the state to solicit subscriptions to a free publication of general interest to members of certain organizations; on receiving such orders, the company would canvass local businesses for paid advertisements to be placed within the publication. The N.Y.S. Department of Taxation and Finance ruled (5) that P.L. 86-272 would not protect the company from New York nexus, as there was no solicitation of sales of tangible personal property. The publication was free to subscribers and P.L. 86-272 does not protect the solicitation of advertising sales, because the Department does not view the sales as tangible personal property. Thus, the company was subject to state franchise tax.

* North Carolina

The DOR announced (6) a change in position on when an investment partnership is doing business in the state. Under the new policy, a partnership engaged solely in investment activities is not considered to be doing business in North Carolina.

* Pennsylvania

Act 89 (HB 1848) expanded nexus to include a corporation (whether in its own name of through any person, association, business trust, corporation, joint venture, LLC, limited partnership, partnership or other entity) engaged in any of the following within Pennsylvania: (1) doing business; (2) carrying on activities including solicitation; (3) employing or using capital; and (4) owning property. The legislation also "clarified" that, for nexus purposes, a corporation's interest in a noncorporate entity is considered a direct ownership interest in the assets, rather than an intangible interest.

In Schering-Plough Healthcare Products Sales Corp, (7) the Commonwealth Court held that it was not necessary for a sales company soliciting sales for its parent to actually have title to goods to qualify for P.L. 86-272 protection. The court based its opinion on the statute's plain wording and the extensive legislative history. Accordingly, "it cannot seriously be argued that a company which limits its activity in a state to a solicitation of orders for goods to which it will never take title has a greater nexus to that state than a company taking similar orders for goods it owns someplace else."

* Tennessee

The DOR explained (8) that an out-of-state limited partnership registered to do business in the state and disregarded for Federal income tax purposes, will not create nexus for its two out-of-state single-member LLC partners, owned by an S corporation without Tennessee nexus. However, the limited partnership will be subject to the state's minimum franchise tax, because it is registered to do business in the state, and will be subject to both excise and franchise taxes if it does business in the state sufficient to establish nexus. The DOR noted that mere registration of the partnership, without more, does not rise to the level of "doing business."

The Court of Appeals found (9) that "there are a substantial number of businesses in Tennessee helping to make the AOL service available to Tennessee customers," and reversed and remanded the Chancery Court of Davidson County's no-nexus summary judgment.

* MTC Factor-Presence Nexus Standards

The Multistate Tax Commission (MTC) has adopted a factor-presence nexus standard for business activity taxes, under which nexus is established for an entity not protected under P.L. 86-272 if any of the following thresholds is exceeded during the tax period: (1) $50,000 of property; (2) $50,000 of payroll; (3) $500,000 of sales; of (4) 25% of total property, payroll or sales. Under this standard, businesses have nexus in states in which they have a significant customer base, whether or not they have a physical presence. The standard was adopted by adding it to the policy statement titled "Ensuring the Equity, Integrity and Viability of State Income Tax Systems"; it encourages Congress to repeal P.L. 86-272 for states that adopt the standard. At press time, no state has adopted this standard.

State Tax Base

The majority of states imposing a corporate income-based tax begin the computation of state taxable income with taxable income as reflected on the Federal corporate income tax return (Form 1120, U.S. Corporate Income Tax Return). These states use either taxable income before net operating loss (NOL) and special deductions (Line 28) or taxable income (Line 30); certain state-specific addition and subtraction modifications are then applied to arrive at the state tax base. Below is a summary of the recent significant changes to the states' tax bases.

* Nonconformity to Bonus Depreciation

The Job Creation and Worker Assistance Act of 2002 provides an additional first-year depreciation deduction or "bonus" equal to 30% of the adjusted basis of qualified property. Due to the negative revenue effect, a number of taxing jurisdictions (e.g., Arizona, Arkansas, Connecticut, District of Columbia, Hawaii, Illinois, Indiana, Iowa, Maine, Maryland, Massachusetts, Minnesota, New Jersey, New York City, Oklahoma, Pennsylvania, Rhode Island, Vermont and Wisconsin) either decoupled from conformity to the Federal depreciation provisions or did not update their conformity to the Internal Revenue Code (IRC) to include the Federal bonus depreciation provisions. (10) A number of other states enacted legislation that requires addback of a portion of the bonus depreciation.

Dividend-Related Deductions

* Arizona

Effective Dec. 31, 2001, HB 2088, Laws 2002, repealed the former corporate deduction for dividends received from companies doing 50% or more of their business in Arizona. The deduction for dividends received from 50%-owned-or-controlled corporations and foreign dividends was retained.

* California

A Los Angeles Superior Court held that California's full or part-a1 disallowance of dividends received from corporations doing business outside the state impermissibly burdens interstate commerce. (11) The court sought further briefing on the appropriate remedy resulting from its ruling. In its Brief on Remedy dated Feb. 22, 2002, the Franchise Tax Board (FTB) took the position that the court's ruling invalidates Rev. & Tax Code Section 24402 retroactively in its entirety; thus, the deduction is denied to all taxpayers for all open years under the normal four-year statute of limitations. Because the California Constitution requires the FTB to enforce Section 24402 until an appellate court has found it unconstitutional, the FTB asked the trial court to: (1) hold its judgment in abeyance until the state Court of Appeal determines the constitutionality of the section; or (2) order the FTB to assess and collect taxes from taxpayers who received the benefit of the section (but stay the judgment until the Court of Appeal determination). The trial court rejected those requests and granted the plaintiff a refund in May, 2002. An appeal has been filed with the Court of Appeal.

* Massachusetts

The Massachusetts DOR announced (12) that "[n]o recipient, including corporations and financial institutions, that receives distributions of income from REITs is allowed to deduct such distributions from gross income as dividends received." The DOR contends that dividend distributions from a captive real estate investment trust (REIT) are not dividends for purposes of the 95% dividends-received deduction (DRD).

* New Jersey

For tax years beginning after 2001, the NJBTA eliminated the 50% deduction for dividends received from a corporation in which the tax-payer holds less than a 50% ownership interest.

* North Carolina

In 2001, the DRD provisions were repealed and replaced with conformity to the Federal DRD rules, thus opening companies up to NCGS 105-130.5(c)(3), which disallows direct and indirect expenses connected with "income not taxed." As a fix, HB 1670, Laws 2002, caps the related expenses that have to be netted against deductible dividends at 15% of dividends for most companies; 20% of dividends for bank holding companies; and 15% of total interest expense for electric-power holding companies. Also, the additional tax that a bank holding company and related companies are required to pay as a result of expense netting is capped at $11 million per corporate group.

* Ohio

In City of Columbus v. New Plan Realty Trust, (13) the Ohio Supreme Court ruled that a REIT may not subtract dividends paid to its shareholders from its taxable income because they are not ordinary and necessary expenses under the local ordinance. Similarly, the Ohio Court of Appeals, First Appellate District, ruled (14) that for Cincinnati tax purposes, a REIT cannot deduct dividends paid to shareholders.


* California

Among other provisions, AB 2065, Laws 2002, suspends NOL deductions for 2002 and 2003, and for tax years beginning after 2003, increases the NOL carryover to 100%.

* Delaware

The Tax Appeal Board ruled (15) that a corporate taxpayer is entitled to carry forward its NOLs to offset income allocated to Delaware.

* Illinois

SB 2212, Laws 2002, limits the ability of taxpayers and the DOR to recalculate a prior-year Illinois NOL carryover. The DON can decrease a loss only if it "notified" the taxpayer within three years after the return for the loss year was filed or, if that period has expired, within one year after the taxpayer filed an amended return increasing the loss (in which case, the DOR's decrease could not exceed the increase claimed by the taxpayer). Similarly, taxpayers cannot claim or increase a loss except by filing an original or amended return for the loss year within three years after the extended due date of the loss-year return.

* Massachusetts

The Appellate Tax Board ruled (16) that a corporate taxpayer may not use an NOL carryforward generated by other corporations. It also ruled (17) that NYNEX could not deduct NOLs of its subsidiaries included in a combined state return. An NOL carryforward is available only to the corporation that created the loss, not on the group's combined tax return.

* New Jersey

Sweeping corporate tax changes in the NJBTA included suspension of the NOL deductions for 2002 and 2003. Also, the New Jersey Tax Court denied (18) the use of a predecessor's NOL under the principles of Richard} Auto City. (19) "New" A.H. Robins, an American Home Products subsidiary, acquired and merged "Old" A.H. Robins from a bankruptcy-related reorganization.

* Pennsylvania

HB 1848, Act 89, increased the NOL carryover period to 10 years.

* Ohio

In A.H. Robins Company Inc., (20) the Board of Tax Appeals considered whether a successor ("Robins II") in a Dec. 15, 1989 merger/tax-free reorganization was able to use the predecessor's ("Robins I") NOL incurred from Jan. through Dec. 15, 1989, on its 1990 state corporate franchise tax report. The Board found that "Robins I" did not exist on Jan. 1, 1990; thus, it was not a taxpayer for franchise tax purposes. The Board also found that the 1989 operations did not constitute a "taxable year" for "Robins I." Because "Robins I" was not a taxpayer, and because the Jan. 1-Dec. 15, 1989 period was not a tax year, it did not have an Ohio NOL to which Robins II could succeed and use.

Other Modifications

* California

The past year brought the state into closer conformity with Federal income tax rules. Key provisions of AB 1122 and SB 657, Laws 2002, include (1) pension, IRA and qualified tuition-contribution limit conformity to the Economic Growth and Tax Relief Reconciliation Act of 2001; (2) conformity to the Federal $1 million executive-compensation deduction rules; (3) denial of deductions for club dues; (4) disallowance of deductions for lobbying expenses; (5) requirement of mandatory California S election if a Federal S election is made; (6) conformity to 2002 Federal legislation preventing the deduction of suspended losses after realization of tax-exempt cancellation of debt income (for tax years ending after 2002); (7) elimination of contribution of appreciated property as a tax preference item for alternative minimum tax purposes; and (8) allowance of deduction for appreciated value of stock contributed to private foundations.

Among other provisions, AB 2065, Laws 2002, eliminates the bad-debt reserve method for large banks (thus conforming to the Federal bad-debt provisions) and reduces the overpayment interest rate. This legislation requires that 50% of the applicable excess bad-debt reserves be taken into income in 2002; the remaining 50% is never taken into income.

* Indiana

The DOR concluded (21) that the Washington business and occupation tax is "measured by income" and, thus, must be added back in computing the state tax base.

* Massachusetts

The Appeals Court held (22) that the taxpayer had failed to sustain its burden of proving that a promissory note, which it declared as a dividend to its parent corporation, was true debt; thus, the taxpayer could not claim an interest expense deduction. Also, for purposes of calculating the net-worth measure of the state excise tax, the taxpayer could not treat the note amount as a liability.

* Michigan

In Columbia Associates L.P., (23) two cable television system operators were unsuccessful in arguing that fees paid to networks for programming (e.g., ESPN, CNN, HBO) should be classified as rents rather than deductible royalties for single business tax purposes.

* New Jersey

Effective for tax years beginning after 2001, the NJBTA included a number of other modifications to the tax base, including: (1) in many cases, disallowing any deduction for research and experimental (R&E) expenditures for which a New Jersey R&E credit is claimed; and (2) disallowing deductions for interest expenses and intangible costs paid to a related entity, unless a taxpayer meets certain stated exceptions.

* North Carolina

The DOR announced (24) that IRC Sec. 338(h)(10) applies for North Carolina income tax purposes for transactions occurring after May 31, 2002. Historically, taxpayers were prohibited from adopting the Federal tax treatment of an IRC Sec. 338(h)(10) election for North Carolina tax purposes, because the state does not allow consolidated return filing. When a valid Federal election is made, the North Carolina filing periods mirror the Federal filing periods. The DOR further explained that the gain from the deemed asset sale is apportionable business income, because the assets are integral to the target's trade or business operations. However, gross receipts from the deemed sale are excluded from the sales factor as a casual sale, because the target does not produce or acquire the assets for sale in the regular course of business.

Business/Nonbusiness Income

Under the Uniform Division of Income for Tax Purposes Act (UDITPA), a multistate corporate taxpayer's income is divided into two classes--business income and nonbusiness income. Business income is divided among the states in which the corporation has nexus by use of a statutory apportionment formula, while nonbusiness income generally is assigned to the state where the corporation is domiciled or the property disposed of is located.

The courts are split as to whether the UDITPA business income definition incorporates two separate, independent tests for business income or a single two-part test using the following requirements: (1) the transaction giving rise to the income is in the regular course of the corporation's income (transactional test); and (2) the acquisition, management, use and disposition of the property are integral parts of the corporation's regular business operations (functional test). In addition to UDITPA's business/nonbusiness distinction, a state is prohibited, under Allied Signal, Inc., (25) from taxing income not generated in the course of the corporation's unitary business. Such income would not be includible in the corporation's apportionable income.

* Arizona

The DOR explained (26) that gain or loss on foreign currency transactions is considered earned in the regular course of a taxpayer's trade or business and is business income when the income results from normal business transactions (e.g., cash deposited in foreign bank accounts or accounts receivable). Gain on foreign currency transactions is nonbusiness income when the investment serves a purely passive investment purpose.

* California

The State Board of Equalization Ruled (27) that Atlantic Richfield Company's (ARCO's) $140 million gain from the sale of 24% of the stock of Britoil was nonbusiness income allocable to California (ARCO's commercial domicile). ARCO purchased the stock in response to a request from Britoil management to block a hostile takeover by British Petroleum. ARCO sold the stock 39 days later after deciding a takeover would be too expensive.

* Illinois

SB 2212, Laws 2002, allows taxpayers to make an annual irrevocable election to treat all income, other than compensation, as "business income" apportionable both in and outside of the state. For tax years beginning after 2002, it allows a taxpayer to separately elect for each tax year.

In Blessing/White, Inc., (28) the appellate court held that income from the sale of substantially all assets of a business was nonbusiness income when the corporation's assets were liquidated, liabilities paid, business ceased and the remaining funds distributed to its shareholders. However, in another case, a circuit judge ruled (29) that IRC Sec. 338(h)(10) taxable gain is business income; the judge deemed that the timing of distribution and gain was sufficient to distinguish Blessing/White.

* Indiana

The DOR found (30) that IRC Sec. 338(h)(10) gain was business income under the functional test, because the income derived from the sale of a business was funneled into a related corporation's business and a business decision was made to acquire, manage and dispose of the income to further the corporation's function.

* Kansas

SB 472, Laws 2002, allows taxpayers to elect to treat all income as business income, effective for the tax year of the election and the following nine tax years. Under prior law, the election applied only to income from the acquisition, management, use or disposition of tangible or intangible property.

* New Jersey

For tax years beginning after 2001, the NJBTA expanded the standard by which nonoperational income can be allocated to the state to the "fullest extent permitted under the Constitution and statutes of the United States."

* North Carolina

For tax years beginning after 2001, SB 1115, Laws 2002, expands the definition of business income to "all income that is apportionable under the U.S. Constitution." In addition, the DOR Explained (31) that the gain from an IRC Sec. 338(h)(10) deemed asset sale is apportionable business income, because the assets are integral to the target's trade or business operations.

* Pennsylvania

The Commonwealth Court held (32) that gain from an I1KC Sec. 338(h)(10) election is business income under the functional test; the court concluded that the reality of the transaction is not a liquidation, but a stock sale.


* Indiana

The DOR disallowed (33) royalty and interest deductions paid to a related Delaware holding company (DHC), ruling that the initial transfer of intellectual property to the DHC and the consequent payment of royalty fees and interest lacked economic substance.

* Louisiana

The Court of Appeal, First Circuit, Held (34) that a Delaware finance holding company was not subject to Louisiana tax. The sole purpose of the DHC was to receive dividends and make loans to related entities, and the corporation had no presence in Louisiana beyond owning stocks in various subsidiary corporations and receiving dividends from them. According to the court, a nonresident parent company is not subject to Louisiana jurisdiction merely because of the existence of its subsidiaries in Louisiana.

* Massachusetts

In Syms Corp., (35) the Supreme Judicial Court upheld the disallowance of deductions for trademark/tradename royalties paid to a DHC on three alternative grounds: (1) the transfer and leaseback of the marks was a sham and could be disregarded under the "sham transaction doctrine"; (2) there was no valid business purpose justifying the expense, and the DHC added little or no value to the marks; and (3) G.L. c. 63, section 39A, permitted the commissioner to eliminate the royalty payments from the calculation of net income, because they were made between affiliated corporations and were in excess of fair value.

In Sherwin-Williams Co., (36) the Supreme Judicial Court upheld deductions for royalties paid to trademark/tradename DHCs used in the parent's business. In reaching its decision, the court concluded that the facts were "substantially different" from those in Syms Corp.

* Missouri

In consolidated cases, (37) the Supreme Court reversed administrative hearing commission decisions and held that captive trademark royalty subsidiaries did not have nexus with the state. According to the court, although the DHCs may be related to companies that conduct business and pay taxes in the state, "they are separate legal entities, and, as such, each must have its own property, payroll or sales in Missouri to be taxed in Missouri."

* North Carolina

The Tax Review Board ruled (38) that a number of DHCs licensing trademarks and tradenames to in-state affiliated entities were doing business in the state. The Board held that licensing intangibles for use in North Carolina and using in-state representatives to establish and maintain ah economic marketplace established sufficient taxable presence to warrant the assessment of corporate income and franchise taxes. The Board relied on principles of trademark law, interpreted as providing that a company's property cannot exist apart from an established business in which it is used, and that if the property is not used, it ceases to exist. The Board also viewed the contractual relationship between DHCs and the affiliated companies as support for finding that the operating companies served as the DHCs representatives or agents within the state.

For more information about this article, contact Ms. Boucher at

(1) See DC Office of Tax and Rev., General Guidance Chart for Nexus, at tax_law.shtm.

(2) FL DOR, TAA 021C1-005 (8/29/02).

(3) Alcoa Building Products, Inc. v. Comm'r of Rev., MA App. Tax Bd., Nos. F257765, F257766 and F257767 (9/25/02).

(4) Matter of Wascana Energy Marketing (U.S.) Inc., NYS Dep't of Tax'n and Fin., No. 817866 (7/18/02, amended 8/18/02).

(5) NYS Dep't of Tax'n and Fin., TSB-A-02(7)C (6/3/02).

(6) NC DOR, Directive PD-02-1 (11/6/02).

(7) Schering-Plough Healthcare Products Sales Corp. v. Comm'th of Pa., PA Comm'th Ct., No. 1015 F.R.1998 (8/28/02).

(8) TN DOR, Rev. Rul. 02-06 (3/18/02).

(9) American Online, Inc. v. Johnson, TN Ct. of Apps., No. M2001-00927-COA-R3-CV (7/30/02).

(10) For details on the states' conformity to the Federal bonus depreciation provisions, see the Federation of Tax Administrators web page, at

(11) Farmer Bros. v. FTB, CA Super. Ct., No. BC237663 (11/21/01 and 5/13/02).

(12) MA DOR, Directive 02-12 (9/17/02).

(13) City of Columbus v. New Plan Realty Trust, OH Sup. Ct., No. 00-1838 (2/6/02).

(14) New Plan Realty Trust, Inc. v. Tax Comm'r of City of Cincinnati, OH Ct. App., 1st Dist., No. C-000748 (10/18/02).

(15) Manufacturing Hanover Leasing Int'l Corp. v. Dir. of Rev., DE Tax App. Bd., No. 1291 (11/1/62).

(16) Macy's East, Inc. v. Comm'r of Rev., MA App. Tax Bd., No. F251009 (11/5/02).

(17) NYNEX Corp. v. Comm'r of Rev., MA App. Tax Bd., No. F233865 (12/19/02).

(18) A.H. Robins Co., Inc. v. Dir., Div. of Tax'n, NJ Tax Ct., No. 005682-95 (2/21/02).

(19) Richard's Auto City, 140 NJ 523 (1995).

(20) A.H. Robins Company, Inc. v. Tracy, OH Bd. of Tax Appeals, No. 97-T1215 (6/14/02).

(21) IN Dep't of State Rev., Letter of Finding No. 93-0962 (7/1/02).

(22) Overnite Transportation Co. v. Comm'r of Rev., 54 Mass. App. Ct. 180 (2002).

(23) Columbia Assocs. L.P.v. Mich. Treas. Dep't, 649 NW2d 760 (MI Ct. App. 2002).

(24) NC DOR, Directive No. CD-02-3 (5/31/02).

(25) Allied Signal, Inc. v. New Jersey, 112 S.Ct. 2251 (1992).

(26) AZ DOR, CT1K 02-4 (8/12/02).

(27) Appeal of Atlantic Richfield Company, CA St. Bd. of Equalization (unpublished decision).

(28) Blessing/White, Inc. v. The State of Ill. DOR, IL Ct. App., No. 1-01-0733 (3/29/02).

(29) American States Ins. Co. v. The State of Ill. DOR, IL Cir. Ct. Cook Cty. (12/11/02).

(30) IN DOR, Letter of Finding 98-0523 (11/01/02).

(31) NC DOR, Corp. Dir. CD-02-3 (5/31/02).

(32) Canteen Corp. v. Comm'th of Pa., 792 A2d 14 (PA Comm'th Ct. 2002); see also Osram Sylvania Inc. v. Comm'th of Pa., PA Comm'th Ct., No. 310 F.R. 1998 (6/19/02).

(33) IN DOR, Letter of Finding No. 01-0063 (10/1/02).

(34) Kevin Assoc. LLC v. Crawford, 2001 CA 2652 (La. Ct. of App., 1st Cir. 11/9/02).

(35) Syms Corp. v. Mass. Comm'r of Rey., 436 Mass. 505 (2002).

(36) Sherwin-Williams Co. v. Mass. Comm'r of Rev., MA Sup. Jud'l Ct., No. SJC-08516 (10/31/02); see King and Rhines, Tax Clinic, "Sherwin-Williams Can Deduct Intercompany Royalties and Interest," 34 The Tax Adviser 83 (February 2003).

(37) ACME Royalty Co. v. Mo. Dir. of Rev., and Gore Ent. Holdings, Inc., MO Sup. Ct., Nos: SC84225 and SC84226 (11/26/02).

(38) A&F Trademark Inc., NC Tax Rev. Bd., No. 381 (5/07/02).

Karen J. Boucher, CPA Senior Manager Deloitte & Touche LLP Milwaukee, WI
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Title Annotation:part 1
Author:Boucher, Karen J.
Publication:The Tax Adviser
Date:Mar 1, 2003
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