Amicus Brief Filed in State Tax Case
Dan De Jong, staff liaison to the State and Local Tax Committee
State and Local Tax - 11/12/2012


On October 26, 2012, TEI filed a brief as amicus curiae with the U.S. Supreme Court in a case involving the characterization of income from the sale of assets as apportionable business income versus allocable nonbusiness income for state tax purposes. The Institute's brief urged the high court to reverse lower court decisions in Alabama holding that gain from the sale of property used in a taxpayer's unitary business constituted nonbusiness income allocable in full to Alabama. The brief was prepared under the aegis of TEI's State and Local Tax Committee, whose chair is Howard E. Grindle of XO Communications. Daniel B. De Jong, TEI Tax Counsel, serves as legal staff liaison to the State and Local Tax Committee and coordinated the preparation of TEI's brief.

View full amicus brief