At&T Corp. & Includible Subsidiaries v. Department of Revenue

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• distinguishing property and payroll factors’, which “estimate the state’s share of responsibility for the income stream by focusing on production” from the sales factor, which “generally tracks the extent to which the taxpayer takes advantage of the taxing state's market”
• refer- ring to “nowhere income” arising from sale of tangible per- sonal property “when the taxpayer cannot be taxed in the purchaser’s state”
• “[c]ommentators have routinely criticized [Section 17 of the Uniform Act] for its ambiguity”
• identifying direct costs of a telephone call

Source: CourtListener parenthetical corpus (CC0).