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DIRECTV, INC. v. DEPARTMENT OF REVENUE

Opinion No. Op. 5513.

421 S.C. 59 (2017)

804 S.E.2d 633

DIRECTV, INC. & SUBSIDIARIES, Appellant, v. SOUTH CAROLINA DEPARTMENT OF REVENUE, Respondent.

Court of Appeals of South Carolina.

Filed August 30, 2017.

Attorney(s) appearing for the Case

John C. von Lehe, Jr. and Bryson M. Geer , both of Nelson Mullins Riley & Scarborough, LLP, of Charleston, for Appellant.

Nicole M. Wooten , William J. Condon, Jr. , and Milton G. Kimpson , all of the South Carolina Department of Revenue, of Columbia, for Respondent.

In this appeal from the administrative law court (ALC), DIRECTV, Inc. & Subsidiaries (DIRECTV) argue the ALC erred in (1) applying an improper burden of proof, (2) holding DIRECTV's income-producing activities (IPA) consisted solely of signal delivery into its customers' homes, (3) finding DIRECTV failed to establish the portion...

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