Vermont Statutes Annotated

Vt. Stat. Ann. tit. 32, § 5833 (2026)

✓ current as of May 2026
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Subchapter 003 : TAXATION OF CORPORATIONS

(Cite as: 32 V.S.A. § 5833)
Notes of Decisions
Cited in 6 cases, 1972–2019 · leading case: Tarrant v. Dep't of Taxes, 733 A.2d 733 (Vt. 1999).
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Tarrant v. Dep't of Taxes, 733 A.2d 733 (Vt. 1999). · cites it 4× “See 32 V.S.A. § 5833. That is, as opposed to a credit for non-Vermont income, § 5833 provides from the outset for allocation of income according to its state source.”
FW Woolworth Co. v. Comm'r of Taxes of State, 328 A.2d 402 (Vt. 1974). · cites it 14× “This formula allocates to Vermont a fair and equitable portion of taxable income of a corporation under the laws of the United States utilizing three factors: (1) the ratio of all real and tangible property within Vermont to all such property both within and without Vermont; (2)…”
In Re Goodyear T. & R. Co., Corp. Income T., 1966, 1967, 1968, 335 A.2d 310 (Vt. 1975). · cites it 15× “This is an appeal from a decision of the Windsor County Court upholding the determination of the Commissioner of Taxes refusing to modify the apportionment formula provided in 32 V.S.A. § 5833 as requested by Goodyear Tire & Rubber Company.”
FW Woolworth Co. v. Comm'r of Taxes, 298 A.2d 839 (Vt. 1972). · cites it 9× “Should the apportionment formula be modified as provided by 32 V.S.A. § 5833 (b) because that formula is intrinsically arbitrary when applied to taxpayers with extensive foreign subsidiary operations?” Woolworth is a New York corporation and has done business in Vermont since…”
Mobil Oil Corp. v. Comm'r of Taxes, 394 A.2d 1147 (Vt. 1978). · cites it 3× “32 V.S.A. § 5833 (a) establishes a procedure for apportioning the net income of a corporation engaging in activity both within and without the state to allocate to Vermont an equitable portion of that income upon which to lay its tax.”
Vermont Nat'l Tel. Co. v. State (Vt. Super. Ct. 2019). · cites it 2× “3 At issue before the Commissioner also was an issue related to VNAT’s 2012 taxes.”
— Vt. Stat. Ann. tit. 32, § 5833(a) — 5 cases
Tarrant v. Dep't of Taxes, 733 A.2d 733 (Vt. 1999). “See 32 V.S.A. § 5833. That is, as opposed to a credit for non-Vermont income, § 5833 provides from the outset for allocation of income according to its state source.”
FW Woolworth Co. v. Comm'r of Taxes of State, 328 A.2d 402 (Vt. 1974). “This formula allocates to Vermont a fair and equitable portion of taxable income of a corporation under the laws of the United States utilizing three factors: (1) the ratio of all real and tangible property within Vermont to all such property both within and without Vermont; (2)…”
FW Woolworth Co. v. Comm'r of Taxes, 298 A.2d 839 (Vt. 1972). “Should the apportionment formula be modified as provided by 32 V.S.A. § 5833 (b) because that formula is intrinsically arbitrary when applied to taxpayers with extensive foreign subsidiary operations?” Woolworth is a New York corporation and has done business in Vermont since…”
In Re Goodyear T. & R. Co., Corp. Income T., 1966, 1967, 1968, 335 A.2d 310 (Vt. 1975). “This is an appeal from a decision of the Windsor County Court upholding the determination of the Commissioner of Taxes refusing to modify the apportionment formula provided in 32 V.S.A. § 5833 as requested by Goodyear Tire & Rubber Company.”
Vermont Nat'l Tel. Co. v. State (Vt. Super. Ct. 2019). “3 At issue before the Commissioner also was an issue related to VNAT’s 2012 taxes.”
— Vt. Stat. Ann. tit. 32, § 5833(b) — 3 cases
FW Woolworth Co. v. Comm'r of Taxes of State, 328 A.2d 402 (Vt. 1974). “This formula allocates to Vermont a fair and equitable portion of taxable income of a corporation under the laws of the United States utilizing three factors: (1) the ratio of all real and tangible property within Vermont to all such property both within and without Vermont; (2)…”
In Re Goodyear T. & R. Co., Corp. Income T., 1966, 1967, 1968, 335 A.2d 310 (Vt. 1975). “This is an appeal from a decision of the Windsor County Court upholding the determination of the Commissioner of Taxes refusing to modify the apportionment formula provided in 32 V.S.A. § 5833 as requested by Goodyear Tire & Rubber Company.”
FW Woolworth Co. v. Comm'r of Taxes, 298 A.2d 839 (Vt. 1972). “Should the apportionment formula be modified as provided by 32 V.S.A. § 5833 (b) because that formula is intrinsically arbitrary when applied to taxpayers with extensive foreign subsidiary operations?” Woolworth is a New York corporation and has done business in Vermont since…”
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