SALT To Taste: Taxpayer Gets "Creamed" Pursuant to Court's Application of the Operational Function Analysis

The Tennessee Supreme Court characterized capital gains recognized as part of a taxpayer's reorganization as apportionable business income under the unitary/operational function test and Tennessee's statutory functional test.  This edition of our newsletter focuses on the Tennessee Supreme Court's application of the operational function analysis while our last newsletter (see "Tennessee Supreme Court Freezes Taxpayer Arguments in Blue Bell Creameries Case") looked at the Court's analysis of the capital gains pursuant to Tennessee's statutory functional test.

Read this SALT To Taste newsletter here.