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SUN FINANCE & LOAN COMPANY v. KOSYDAR

No. 75-105.

45 Ohio St. 2d 283 (1976)

SUN FINANCE & LOAN COMPANY, APPELLEE, v. KOSYDAR, TAX COMMR., APPELLANT.

Supreme Court of Ohio.

Decided March 17, 1976.

Attorney(s) appearing for the Case

Messrs. Walker & Chatfield, Mr. Burgess L. Doan, Mr. Harold W. Walker and Mr. Joseph Beech III, for appellee.

Mr. William J. Brown, attorney general, and Mr. John C. Duffy, Jr., for appellant.

Per Curiam.

The sole issue before this court is whether the business done by Sun's out-of-state consumer finance subsidiaries, which subsidiaries do not operate offices in Ohio, should be included in the R. C. 5725.15 apportionment formula utilized to determine the extent to which Sun's total net worth is to be allocated to Ohio.1

There is no question that Sun is a "dealer in intangibles" as that term is defined in R. C...

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