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ALLIS-CHALMERS CREDIT CORP. v. STATE, ETC.

No. AC-232.

408 So.2d 703 (1982)

ALLIS-CHALMERS CREDIT CORPORATION, Appellant, v. STATE of Florida, DEPARTMENT OF REVENUE, Appellees.

District Court of Appeal of Florida, First District.

January 11, 1982.

Attorney(s) appearing for the Case

Kenneth R. Hart of Ausley, McMullen, McGehee, Carothers & Proctor, Tallahassee, for appellant.

Jim Smith, Atty. Gen., and G.P. Waldbart, Asst. Atty. Gen., Tallahassee, for appellees.

PER CURIAM.

This controversy concerns the apportionment of Allis-Chalmers Credit Corporation's adjusted federal income for taxation under Florida's Income Tax Code, Chapter 220, Florida Statutes. Apportionment is accomplished using a fraction. In the numerator of the fraction are three factors: Florida property, Florida payroll, and Florida sales. The denominator consists of nationwide property, payroll, and sales. The dispute is over whether certain interest income...

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