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MEDIA GENERAL v. S.C. DEPT. OF REVENUE

No. 26828.

388 S.C. 138 (2010)

694 S.E.2d 525

MEDIA GENERAL COMMUNICATIONS, INC., and Media General Broadcasting of South Carolina Holdings, Inc., Respondents, v. SOUTH CAROLINA DEPARTMENT OF REVENUE, Appellant. Media General, Inc., Respondent, v. South Carolina Department of Revenue, Appellant.

Supreme Court of South Carolina.

Decided June 14, 2010.

Attorney(s) appearing for the Case

Lynn M. Baker, Managing Counsel, and Ronald W. Urban, Chief Counsel, both of South Carolina Department of Revenue, of Columbia, for Appellant.

Burnet R. Maybank, III, of Nexsen Pruet, of Columbia, for Respondents.

Justice BEATTY.

The appellant, the South Carolina Department of Revenue ("Department"), contends the Administrative Law Court ("ALC") erred in construing S.C.Code Ann. § 12-6-2320(A)(4) as allowing the three multistate corporations named herein to use the combined entity method in apportioning their income and determining their South Carolina corporate income tax liability. We affirm.

I. FACTS

This taxation case involves three corporations that...

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