Macey, Wilenski & Hennings, L.L.C., and Peter G. Stathopoulos ; and Robert Alt , urging reversal for amici curiae Buckeye Institute for Public Policy Solutions, Mackinac Center for Public Policy, NetChoice, and American Catalog Mailers Association, Inc.
Goldstein & Russell, P.C., Eric F. Citron , and Thomas C. Goldstein , urging affirmance for amici curiae National Governors Association, National Conference of State Legislatures, Council of State Governments, National Association of Counties, National League of Cities, U.S. Conference of Mayors, International City/County Management Association, International Municipal Lawyers Association, and Government Finance Officers Association.
Bricker & Eckler, L.L.P., Mark A. Engel , and Anne Marie Sferra , urging affirmance for amici curiae Ohio Manufacturers' Association, Ohio State Medical Association, Ohio Dental Association, and Ohio Chemistry Technology Council.
Bruce Fort , urging affirmance for amicus curiae Multistate Tax Commission.
KENNEDY, J., dissents, with an opinion joined by LANZINGER, J.
O'NEILL, J.
{¶ 1} Appellant and cross-appellee, Crutchfield Corporation, appeals from the imposition of Ohio's commercial-activity tax ("CAT") on revenue it has earned from sales of electronic products that it ships into the state of Ohio. Crutchfield is based outside Ohio, employs no personnel in Ohio, and maintains no facilities...
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