Wednesday, August 1, 2012

Revenue Finds that Taxpayer Provided Some Evidence that "Throwback Sales" Improper Due to Company Nexus with Other States

The Department made several adjustments to Taxpayer's sales factor. The Department attributed to Indiana certain of the sales made to locations in other states. The Department treated these sales as "throwback" sales attributed to Indiana. IC § 6-3-2-2(e), (n). The decision resulted in an increase in Taxpayer's corporate adjusted gross income tax. Taxpayer protests the Department's assessment of adjusted gross income tax for the 2005, 2006, and 2007 tax years and the Department's denial of its refund for the 2004 tax year based upon these adjustments to its sales factor. Taxpayer maintains that the throw-back rule is not warranted for sales to a number of states.


The Department determined that, for purposes of calculating taxpayer's Indiana tax liability, the receipts from sales to out-of-state customers should be thrown back to Indiana because the sales were made within jurisdictions where the taxpayer did not have nexus with the state. The audit based its decision on Example 5 of 45 IAC 3.1-1-53 which states that "[i]f the taxpayer is not taxable in the state of the purchaser, the sale is attributed to [Indiana] if the property is shipped from an office, store, warehouse, factory, or other place of storage in this state." Such sales are designated as "throw-back" sales. Id.


Taxpayer asserts that it has nexus in several states and, therefore, the throw-back rule is not applicable. Taxpayer maintains that in addition to its sales force in these states, it has employees that supervise clinical trials that are being conducted by independent investigator/physicians. Taxpayer states that these supervisory duties give it nexus in these states where the clinical trials were conducted.

During the protest, Taxpayer provided additional documentation–including supervisors' travel documentation, lists of the clinical trial locations, and supervisors' log sheets. Based upon this documentation, Taxpayer has established that in these states where the clinical trials are located it has "nexus" and, therefore, was subject to "a net income tax, a franchise tax measured by net income, a franchise tax for the privilege of doing business, or a corporate stock tax," sales to customers in these states should not be thrown back to Indiana. Thus, Taxpayer's protest is sustained in part to the extent that sales to these states where Taxpayer presented documentation that clinical trials were being conducted have been thrown back to Indiana. However, Taxpayer's protest is denied to the extent that sales to these states where Taxpayer failed to present documentation of the conducting of the clinical trials. The file will be returned to the audit division where they are requested to review the submitted documentation and make whatever adjustments it deems appropriate.