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MILLWARD BROWN, INC. v. COMMISSIONER OF REVENUE SERVICES

(AC 22258)

73 Conn. App. 757 (2002)

MILLWARD BROWN, INC. v. COMMISSIONER OF REVENUE SERVICES.

Appellate Court of Connecticut

Officially released November 26, 2002

Attorney(s) appearing for the Case

Jonathon L. Ensign, assistant attorney general, with whom, on the brief, were Richard Blumenthal, attorney general, and Edward F. Reynolds, Jr., assistant attorney general, for the appellant (defendant).

Ian E. Bjorkman, with whom were Kenneth D. Heath and, on the brief, Peter H. Gruen, for the appellee (plaintiff).

Mihalakos, Bishop and Peters, Js.

Opinion

PETERS, J.

General Statutes § 12-2141 requires multistate corporations that do business in Connecticut to pay a Connecticut corporate business tax. To determine the amount of a multistate corporation's tax liability, the commissioner of revenue services apportions the corporation's income to Connecticut in accordance with one of the formulae stated in General Statutes § 12-218. The one factor formula...

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