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GEOFFREY, INC. v. OKLAHOMA TAX COM'N

No. 99,938.

132 P.3d 632 (2005)

2006 OK CIV APP 27

GEOFFREY, INC., Appellant, v. The OKLAHOMA TAX COMMISSION, Appellee.

Court of Civil Appeals of Oklahoma, Division No. 1.

Certiorari Denied March 20, 2006.

As Corrected April 12, 2006.

Attorney(s) appearing for the Case

Timothy M. Larason, Andrews Davis, Oklahoma City, OK, and Paul H. Frankel, Morrison & Foerster LLP, New York, NY, for Appellant.

Douglas B. Allen, General Counsel, Lyn Martin-Diehl and J.L. Miller, Assistant General Counsel, Oklahoma Tax Commission, Oklahoma City, OK, for Appellee.

Released for Publication by Order of the Court of Civil Appeals of Oklahoma, Division No. 1.

OPINION

ADAMS, Presiding Judge.

¶ 1 Geoffrey, Inc. (Geoffrey), a Delaware corporation, appeals an Order of the Oklahoma Tax Commission (OTC) imposing corporate income tax on royalties Geoffrey received from the licensing of its intangible personal property during the years at issue, i.e., 1992, 1993 and...

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