In conclusion, the Commission's decision was not arbitrary and capricious. Chief Justice Howe, Associate Chief Justice Durham, Justice Zimmerman and Justice Russon concur in Justice Stewart's opinion. Tax Commission Decision, Appeal No. Tax Commission Decision, Appeal No. Unless otherwise mentioned, identical statutory sections to the sections cited in this opinion were previously found at Utah Code Ann.
Many corporations earn income from business activities in more than one state.
Utah Laws ch. This section is virtually identical to the standard stated in the 1987 Decision and is applicable to the entire corporate income tax chapter, title 59, chapter 7. Utah Code Ann. Steiner Financial comprised a unitary business if they were related through common ownership and their business activities were integrated, dependant and contributed to each other. . . . 1997 Decision at 7-8.