Quimbee logo
DMCA.com Protection Status

Exxon Corporation v. Wisconsin Department of Revenue

447 U.S. 207, 100 S. Ct. 2109 (1980)

Case BriefRelatedOptions
From our private database of 35,400+ case briefs...

Exxon Corporation v. Wisconsin Department of Revenue

United States Supreme Court

447 U.S. 207, 100 S. Ct. 2109 (1980)

Facts

Exxon Corporation (plaintiff) was a petroleum company incorporated in Delaware with its main offices in Texas. Exxon divided its corporate organization into three levels. The third level, operations management, oversaw three functional departments: exploration and production, refining, and marketing. The three departments were treated as separate by Exxon for accounting purposes. Exxon filed income- and franchise-tax returns in Wisconsin. Because Exxon’s only activity in Wisconsin was marketing, Exxon limited its Wisconsin tax returns to its marketing operation in Wisconsin. The Wisconsin Department of Revenue (the revenue department) (defendant) audited Exxon and determined that Exxon was liable for income and franchise taxes on all its income, not just its marketing income. The revenue department applied Wisconsin’s apportionment formula to Exxon’s total income, comprising the income of the three functional departments, to calculate Exxon’s tax deficiencies. Exxon contested the revenue department’s calculations, arguing that the Due Process Clause of the Fourteenth Amendment prevented the revenue department from applying Wisconsin’s tax to all three functional departments because Exxon performed only marketing in the state. The Wisconsin Supreme Court held that the three functional departments of Exxon’s operations-management business constituted a unitary business because Exxon’s production and refinement departments relied on the marketing department to find customers for their products. The court concluded that because Exxon operated a unitary business, all its income was subject to apportionment for Wisconsin income- and franchise-tax purposes. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Marshall, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 617,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 617,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 35,400 briefs, keyed to 984 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 617,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 35,400 briefs - keyed to 984 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership