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GANNETT SATELLITE INFORMATION NETWORK, INC. v. STATE, DEPT. OF REV.

No. DA 08-0026.

201 P.3d 132 (2009)

2009 MT 5

348 Mont. 333

GANNETT SATELLITE INFORMATION NETWORK, INC., Petitioner and Appellant, v. STATE of Montana, DEPARTMENT OF REVENUE, Respondent and Appellee.

Supreme Court of Montana.

Decided January 13, 2009.

Attorney(s) appearing for the Case

For Appellant: Michael W. Green and Joseph P. Mazurek, Crowley, Haughey, Hanson, Toole & Dietrich, Helena, Montana, Scott D. Smith, Attorney at Law, Washington, D.C.

For Appellee: Brendan R. Beatty and Derek R. Bell, Special Assistant Attorneys General, Department of Revenue, Helena, Montana.

For Amicus: Bruce J. Fort, Multistate Tax Commission, Santa Fe, NM, Lawrence A. Anderson, Attorney at Law, Great Falls, Montana (Multistate Tax Commission).

Justice BRIAN MORRIS delivered the Opinion of the Court.

¶ 1 Gannett Satellite Information Network, Inc. (GANSAT) appeals an order of the First Judicial District, Lewis and Clark County. The District Court upheld the Montana State Tax Appeal Board (STAB)'s May 17, 2007, order that defined "business income" under § 15-31-302(1), MCA. We affirm.

¶ 2 We review the following issue on appeal:

¶ 3 Did the District Court properly interpret...

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