Earth Resources Company Alaska v. State

This case involves principles of multistate corporate taxation as set out in the Multistate Tax Compact, AS 43.19.010-43.19.050 and the Alaska Net Income Tax Act, AS 43.20.010-43.20.350 (ANITA). The central issue on appeal is whether the taxpayer was properly found to be a unitary business to which the apportionment formula of AS 43.20.065 must be applied. Additionally, the taxpayer raises questions regarding the standard of review and the burden of proof to be utilized when a taxpayer challenges the Departments application of the apportionment formula.