Case Study: Equifax V. Supreme Court Of Mississippi
The Supreme Court of Mississippi applied the language of the UDIPA that says that tax commissions may require a taxpayer to use an alternate method of allocation and apportionment as long as it is reasonable. Also, the court ruled that the taxpayer, not the tax commission, has to satisfy the burden of proof in a trial court and that based on the decision of the trial court, Equifax did not. After evaluating Equifax’s factual claims that the trial judge did not find that the change in apportionment method to violate the Mississippi Administrative Procedures Act and that the penalties imposed were not arbitrary and capricious, the court analyzed whether the trial judge had committed a manifest-error. The court determined that the judge did not