unitary business principle in Tennessee

5 Tennessee opinions name it 2 courts 1994–2011 0 in the last five years

The cases below were cited by Tennessee courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (4)

Case	Followed	Cited
Allied-Signal, Inc. Ex Rel. Bendix Corp. v. Director, Division of Taxationgreen scotus · 1992 · cited in 4 Tennessee opinions naming this issue, 1996–2011 2 sentences 2011See id. 2011A state may not tax value “derived from an ‘unrelated business activity’ which constitutes a ‘discrete business enterprise.’” Id. at 25 (quoting Allied-Signal, Inc. v. Dir., Div. of Taxation, 504 U.S. 768,778 (1992) (quoting Exxon Corp. v. Dep’t of Revenue of Wisconsin, 447 U.S. 207, 224 (1980)(quoting Mobil Oil, 445 U.S. at 439 )).	2	4
MeadWestvaco Corp. v. Illinois Department of Revenuegreen scotus · 2008 · cited in 2 Tennessee opinions naming this issue, 2011–2011 2 sentences 2011Under the unitary-business principle, “[a] -9- state may . . . tax an apportioned share of the value generated by the intrastate and extrastate activities of a multistate enterprise if those activities form part of a ‘unitary business.’” MeadWestvaco Corp. v. Illinois Dep’t of Revenue, 553 U.S. 16, 19 (2008). 2011Under the unitary-business principle, “[a] -9- state may . . . tax an apportioned share of the value generated by the intrastate and extrastate activities of a multistate enterprise if those activities form part of a ‘unitary business.’” MeadWestvaco Corp. v. Illinois Dep’t of Revenue, 553 U.S. 16, 19 (2008).	2	2
Exxon Corp. v. Department of Revenue of Wis.green scotus · 1980 · cited in 1 Tennessee opinions naming this issue, 2011–2011 1 sentence 2011A state may not tax value “derived from an ‘unrelated business activity’ which constitutes a ‘discrete business enterprise.’” Id. at 25 (quoting Allied-Signal, Inc. v. Dir., Div. of Taxation, 504 U.S. 768,778 (1992) (quoting Exxon Corp. v. Dep’t of Revenue of Wisconsin, 447 U.S. 207, 224 (1980)(quoting Mobil Oil, 445 U.S. at 439 )).	1	1
International Paper Co. v. Commissioner of Revenue Servicesgreen connsuperct · 1992 · cited in 1 Tennessee opinions naming this issue, 1996–1996 2 sentences 1996Allied-Signal, Inc. v. Director, Div. of Taxation, 504 U.S. at 785 , 112 S.Ct. at 2262 ; ASARCO, Inc. v. Idaho State Tax Comm’n, 458 U.S. at 329 n. 24, 102 S.Ct. at 3116 n. 24; International Paper Co. v. Commissioner of Revenue Servs., 42 Conn.Supp. 356 , 621 A2d 330, 332 (1992). 1996Allied-Signal, Inc. v. Director, Div. of Taxation, 504 U.S. at 785 , 112 S.Ct. at 2262 ; ASARCO, Inc. v. Idaho State Tax Comm’n, 458 U.S. at 329 n. 24, 102 S.Ct. at 3116 n. 24; International Paper Co. v. Commissioner of Revenue Servs., 42 Conn.Supp. 356 , 621 A2d 330, 332 (1992).	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Tennessee. Read the followed side critically anyway.

Also cited on this issue (6)

Case	Cited	Years
Mobil Oil Corp. v. Commissioner of Taxes of Vt. green scotus · 1980 2 sentences 2011Mobil Oil Corp. v. Comm’r of Taxes of Vermont, 445 U.S. 425 , 436 -437(1980)(citations omitted). “[T]he linchpin . . . is the unitary-business principle.” Id. at 439 . 2011Mobil Oil Corp. v. Comm’r of Taxes of Vermont, 445 U.S. 425 , 436 -437(1980)(citations omitted). “[T]he linchpin . . . is the unitary-business principle.” Id. at 439 .	3	1994–2011
ASARCO Inc. v. Idaho State Tax Commission green scotus · 1982 2 sentences 1996Allied-Signal, Inc. v. Director, Div. of Taxation, 504 U.S. at 785 , 112 S.Ct. at 2262 ; ASARCO, Inc. v. Idaho State Tax Comm’n, 458 U.S. at 329 n. 24, 102 S.Ct. at 3116 n. 24; International Paper Co. v. Commissioner of Revenue Servs., 42 Conn.Supp. 356 , 621 A2d 330, 332 (1992). 1994In Asarco the court observed that the “unitary business limitation” for state apportionment is similar to the due process requirements of “a minimal connection between the interstate activities of the taxing state and a rational relationship between the income attributed to the state and intrastate values of the enterprise.” Asarco, 458, U.S. at 316, 102 S.Ct. at 3109 , 73 L.Ed.2d at 795 .	2	1994–1996
Louis Dreyfus Corp. v. Huddleston green tennctapp · 1996 1 sentence 1999In support of that assertion, LMB would point the court to our decision on Louis Dreyfus Corp. v. Huddleston, 933 S.W.2d 460 (Tenn. Ct. App. 1996). 9 The commissioner attempts to simplify the discussion below and on appeal to suggest one of two alternative tests.	1	1999–1999
Underwood Typewriter Co. v. Chamberlain green scotus · 1920 2 sentences 1999Thus, in Underwood Typewriter Co. v. Chamberlain, 254 U.S. 113, 120-121 , 41 S.Ct. 45, 47 , 65 L.Ed. 165 (1920), we explained: “The profits of the corporation were largely earned by a series of transactions beginning with manufacture in Connecticut and ending with the sale in other States. 1999Thus, in Underwood Typewriter Co. v. Chamberlain, 254 U.S. 113, 120-121 , 41 S.Ct. 45, 47 , 65 L.Ed. 165 (1920), we explained: “The profits of the corporation were largely earned by a series of transactions beginning with manufacture in Connecticut and ending with the sale in other States.	1	1999–1999
Goldberg v. Sweet green scotus · 1989 2 sentences 1996Oklahoma Tax Comm’n v. Jefferson Lines, Inc., — U.S. -, -, 115 S.Ct. 1331, 1338 , 131 L.Ed.2d 261 (1995); Goldberg v. Sweet, 488 U.S. 252, 260-61 , 109 S.Ct. 582, 588 , 102 L.Ed.2d 607 (1989). 1996Oklahoma Tax Comm’n v. Jefferson Lines, Inc., — U.S. -, -, 115 S.Ct. 1331, 1338 , 131 L.Ed.2d 261 (1995); Goldberg v. Sweet, 488 U.S. 252, 260-61 , 109 S.Ct. 582, 588 , 102 L.Ed.2d 607 (1989).	1	1996–1996
Oklahoma Tax Commission v. Jefferson Lines, Inc. red scotus · 1995 2 sentences 1996Oklahoma Tax Comm’n v. Jefferson Lines, Inc., — U.S. -, -, 115 S.Ct. 1331, 1338 , 131 L.Ed.2d 261 (1995); Goldberg v. Sweet, 488 U.S. 252, 260-61 , 109 S.Ct. 582, 588 , 102 L.Ed.2d 607 (1989). 1996Oklahoma Tax Comm’n v. Jefferson Lines, Inc., — U.S. -, -, 115 S.Ct. 1331, 1338 , 131 L.Ed.2d 261 (1995); Goldberg v. Sweet, 488 U.S. 252, 260-61 , 109 S.Ct. 582, 588 , 102 L.Ed.2d 607 (1989).	1	1996–1996

Statutes the citing opinions construe

TN § Tenn. Code Ann. § 67-1-1803 (4) TN § Tenn. Code Ann. § 67-4-804 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

OR 14 (1993–2023) CA 10 (1970–2018) NJ 9 (1983–2011) IL 8 (2000–2005) MN 7 (1984–2025) MO 7 (1983–1998) MI 6 (2005–2023) MD 6 (1984–2019) TN 5 (1994–2011) IN 4 (1999–2017) NM 4 (1993–2024) PA 3 (1995–2013) OK 2 (1994–1994) ME 2 (2007–2021) NY 2 (1986–1991) CO 2 (1983–1999) AZ 2 (2010–2013) AK 2 (1983–1998) WI 2 (1993–1994) KY 2 (1994–2009) ND 2 (1991–2005)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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