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INTERNATL. PAPER CO. v. TESTA

No. 2014-1614.

150 Ohio St.3d 348 (2016)

2016-Ohio-7454

INTERNATIONAL PAPER COMPANY, APPELLEE, v. TESTA, TAX COMMR., APPELLANT.

Supreme Court of Ohio.

Decided October 26, 2016.

Attorney(s) appearing for the Case

Zaino, Hall & Farrin, L.L.C., Thomas M. Zaino , and Richard C. Farrin , for appellee.

Michael DeWine , Attorney General, and Barton A. Hubbard , Assistant Attorney General, for appellant.

{¶ 1} This case presents an issue concerning the credit available under the commercial-activity tax ("CAT"), which permits taxpayers to realize some benefit from net operating losses ("NOLs") now that Ohio's corporate-franchise tax has been replaced by the CAT. As we explained in Navistar, Inc. v. Testa,

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