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Table of Authorities ii
BerwindWhite Coal Mining Co 309
Motion for Lease to File Supplemental Brief for
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activities in Vermont allocation amicus curiae appeal Appellant’s Appellee apportioned net income apportionment formula argument Arizona attributable beneﬁts Buck Act burden business activities business situs California Commerce Clause commercial domicile Company Complete Auto Transit conﬂict Cong Congress constitutional corporation’s decision dends dividend income dividends received domestic corporations double taxation Due Process Clause fact federal taxable income foreign source dividends Gila River handwriting exemplars imposed included income tax Indian reservation intangible Internal Revenue Service interstate commerce investment issue Japan Line jurisdiction ment merce Mobil Moorman multiple taxation net income operating petroleum proﬁts question risk of multiple rules Section Sess speciﬁc Stat statute subsidiaries summons supra tax base Tax Commission tax purposes tax treaties taxation of foreign Taxation of Interstate taxpayer tion transaction transaction privilege tax Tribe UDITPA unitary business United Vermont Supreme Court Vermont tax Washington Yes Yes York