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UNIV. OF PHOENIX v. DEPT. OF STATE REV.

Cause No. 49T10-1411-TA-00065.

88 N.E.3d 805 (2017)

The UNIVERSITY OF PHOENIX, INC., Petitioner, v. INDIANA DEPARTMENT OF STATE REVENUE, Respondent.

Tax Court of Indiana.

Filed November 30, 2017.

Attorney(s) appearing for the Case

ATTORNEYS FOR PETITIONER: RANDAL J. KALTENMARK , ZIA MOLLABASHY , BARNES & THORNBURG LLP, Indianapolis, IN, JENNY A. AUSTIN , THEODORE R. BOTS , BAKER & McKENZIE LLP, Chicago, IL, SCOTT L. BRANDMAN , BAKER & McKENZIE LLP, New York, NY

ATTORNEYS FOR RESPONDENT: CURTIS T. HILL, JR. , INDIANA ATTORNEY GENERAL, WINSTON LIN , PARVINDER K. NIJJAR , DEPUTY ATTORNEYS GENERAL, Indianapolis, IN

The University of Phoenix, Inc. challenges the Indiana Department of State Revenue's assessments of adjusted gross income tax (AGIT) for the 2009, 2010, and 2011 tax years. The question is whether the University's online campus revenue can be sourced to Indiana based on a student's Indiana billing address. The Court finds that it cannot...

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