NO. 03-14-00197-CV.

471 S.W.3d 138 (2015)

GRAPHIC PACKAGING CORPORATION, Appellant v. Glen HEGAR, Comptroller of Public Accounts of The State of Texas; and Ken Paxton, Attorney General of The State of Texas, Appellees.

Court of Appeals of Texas, Austin.

Filed: July 28, 2015.

Attorney(s) appearing for the Case

James F. Martens , Amanda G. Taylor , Danielle V. Ahlrich , Lacy L. Leonard , Martens Todd Leonard Taylor & Ahlrich, Austin, TX, Edwin P. Antolin , Amy L. Silverstein , Silverstein & Pomerantz, LLP, San Francisco, CA, for Appellant.

Cynthia A. Morales , Assistant Attorney General, Rance Craft , Office of the Attorney General, Austin, TX, for Appellees.

Before Chief Justice Rose, Justices Goodwin and Field


This appeal presents the issue of how a taxpayer apportions the share of its taxable margin to its Texas operations for franchise tax purposes. According to the Comptroller of Public Accounts and the Attorney General (collectively the Comptroller), a taxpayer may not use the three-factor formula...

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