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MOORMAN MFG. CO. v. BAIR

No. 77-454.

437 U.S. 267 (1978)

MOORMAN MANUFACTURING CO. v. BAIR, DIRECTOR OF REVENUE OF IOWA.

Supreme Court of United States.

Decided June 15, 1978.

Attorney(s) appearing for the Case

Donald K. Barnes argued the cause for appellant. With him on the briefs were Walter R. Brown, John V. Donnelly, Carl G. Schmiedeskamp, and Robert W. Cook.

Harry M. Griger, Assistant Attorney General of Iowa, argued the cause for appellee. With him on the brief was Richard C. Turner, Attorney General.*

James L. Rogers, John R. Phillips, and Philip B. Kurland filed a brief for the Iowa Manufacturers Assn. et al. as amici curiae urging affirmance.

Willam D. Dexter, James A. Redden, Attorney General of Oregon, and Theodore W. deLooze, Assistant Attorney General, filed a brief for the Multistate Tax Comm'n et al. as amici curiae.

MR. JUSTICE STEVENS delivered the opinion of the Court.

The question in this case is whether the single-factor sales formula employed by Iowa to apportion the income of an interstate business for income tax purposes is prohibited by the Federal Constitution.

I

Appellant, Moorman Manufacturing Co., is an Illinois corporation engaged in the manufacture and sale of animal feeds. Although the products it sells...

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