Patton R. Corrigan v. Joseph W. Testa, Tax Commissioner of Ohio, Case No. 2014-1836

Ohio Board of Tax Appeals

ISSUES:

-Do the due process and commerce clauses of the U.S. Constitution bar Ohio from levying an apportioned income tax on the financial gains earned by a nonresident from a closely held Ohio corporation?

-Does Ohio law violate the due process and commerce clauses of the U.S. Constitution because it apportions gains recognized by residents and nonresidents?