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NOELL INDUSTRIES v. IDAHO STATE TAX COM'N

Docket No. 46941.

470 P.3d 1176 (2020)

NOELL INDUSTRIES, INC., a Virginia corporation, Plaintiff-Respondent, v. IDAHO STATE TAX COMMISSION, Defendant-Appellant.

Supreme Court of Idaho, Boise, January 2020 Term.

Rehearing Denied August 14, 2020.

Attorney(s) appearing for the Case

Lawrence G. Wasden , Idaho Attorney General, Boise, for Appellant. Nathan H. Nielson argued.

Hawley Troxell Ennis & Hawley, LLP, Boise, for Respondent. Richard G. Smith argued.

This case concerns a straightforward issue of tax law: whether the gain from the sale of an ownership interest in a legal entity constituted "business income" under Idaho Code section 63-3027. In 2010, Noell Industries, Inc. sold its interest in a limited liability company for a net gain of $120 million. Noell Industries reported...

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