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EXXON CORP. v. WISCONSIN DEPT. OF REVENUE

No. 79-509.

447 U.S. 207 (1980)

100 S.Ct. 2109

65 L.Ed.2d 66

EXXON CORP. v. DEPARTMENT OF REVENUE OF WISCONSIN.

Supreme Court of United States.

Decided June 10, 1980.

Attorney(s) appearing for the Case

Thomas G. Ragatz argued the cause for appellant. With him on the briefs were Leonard S. Sosnowski, Lloyd M. McBride, and Paul D. Frenz.

Gerald S. Wilcox, Assistant Attorney General of Wisconsin, argued the cause for appellee. With him on the brief was Bronson C. La Follette, Attorney General.*

Briefs of amici curiae were filed by Theodore J. Carlson, Davison W. Grant, Joseph J. Schumm, Jr., and Thomas C. Hutton for Associated Dry Goods Corp.; and by Frank M. Keesling, pro se.

MR. JUSTICE MARSHALL delivered the opinion of the Court.

This case raises three important questions regarding state taxation of the income of a vertically integrated corporation doing business in several States. The first issue is whether the Due Process Clause of the Fourteenth Amendment prevents a State from applying its statutory apportionment formula to the total corporate income of the taxpayer when the taxpayer's functional...

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