Top State Corporate Income Tax Cases of 2019: Nexus, Business Income, Combined Reporting, and Apportionment

Recording of a 110-minute CPE webinar with Q&A

Conducted on Wednesday, November 13, 2019

Recorded event now available

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Course Materials

This course will provide tax professionals with an instructive review of the top state corporate income tax cases from 2019. Our panel will discuss SALT cases spanning substantive areas including nexus, apportionment, non-business income, the tax base, sales factor sourcing, and unitary combined reporting.


Every year auditors launch hundreds of state corporate income tax audits. The audits focus on a variety of substantive areas including nexus, PL 86-272, apportionment, the sales factor, sourcing, non-business income, the unitary business concept, and combined reporting. The panelists selected cases to review for their educational value and significance and include examples from California, New York, and many states in between.

Of these hundreds of newly launched audits, most settle at the audit or initial appeal stage--very few cases make it to a litigated decision.

Listen as our expert panel analyzes and dissects the most significant state corporate income tax cases that were not settled and proceeded to a litigated decision issued in 2019.



  1. Summary of case selection process
  2. Top nexus/PL 86-272 cases
  3. Top apportionment cases
  4. Top combined reporting cases
  5. Top tax base cases
  6. Top overall cases


The panel will discuss these and other essential questions:

  • Potential reasons why these cases were litigated and not settled
  • Key facts in the cases that were determinative of the outcome
  • Trends that can be derived from these cases
  • Lessons from the cases with respect to meeting the burden of proof
  • Audit and state tax controversy tips from the cases


Cataldo, Michael
Michael J. Cataldo

Cataldo Tax Law

Mr. Cataldo represents corporate and individual clients in state and local tax controversies across the country during...  |  Read More

Reed, Jeffrey
Jeffrey S. Reed

Kilpatrick Townsend & Stockton

Mr. Reed chairs the firm's State and Local Tax Practice. He helps tax directors, business owners, and individuals...  |  Read More

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