TAX 9866 Lecture Notes - Lecture 40: Pharmaceutical Industry, Underwood Typewriter Company
Document Summary
First division = chemicals second = human pharma three= vet pharma can argue 3 or 2 or 1 biznesses (big chemical company) Allocation of expenses to unitary + nonunitary divisions lets say single company and they are in two different businesses. Under california law, the investment was if company hq in cali then cail got. Entirely alloc to hq state if hq outside of cali then cali got none. But if in state, gaining full use of interest exp. Goes to ussc and says discrim against interstate commerce. Cannot have apportionment unless unitary biz if multiple unitary biz then multiple pies. Fair apportionment has a single pie and we"re concerned w/ how state asks us to divide up pie does that lead to a fair result. Comp underwood has factory in one state ct. Have network of salesmen and sell typewriters in other 49 states. State by state basis: making $ in 49 states but lost $ in connecticut.
