COMPTROLLER OF TREASURY, IT DIV. v. Armco, Inc.

How courts have described this case

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

• recognizing that the “Supreme Court has consistently applied an analysis keyed to ‘economic realities’ ”
• stating that “the constitutionality of the State tax is presumed, and the taxpayer has the distinct burden of showing by clear and cogent evidence that the State tax results in extra-territorial [and hence unconstitutional] values being taxed”
• agreeing with the position of the Tax Court that it lacked authority to allow an exclusion from taxable income on the ground that the exclusion was required by the Commerce Clause

Source: CourtListener parenthetical corpus (CC0).