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TGS–NOPEC Geophysical Co. v. Combs

340 S.W.3d 432 (2011)

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TGS–NOPEC Geophysical Co. v. Combs

Texas Supreme Court

340 S.W.3d 432 (2011)

Facts

TGS–NOPEC Geophysical Company (TGS) (plaintiff) was a Delaware corporation with its principal place of business in Houston, Texas. TGS was in the business of gathering, interpreting, and marketing seismic and geophysical data that was useful in oil- and gas-drilling operations. TGS collected and stored the data in a master library, which it licensed parts of to its customers. For tax purposes, TGS characterized its revenue from the license agreements as sales of intangible assets. Under the relevant provisions of the Texas tax code, such income was allocated to the state of the payor’s domicile, which for TGS was Delaware. After an audit, the Texas comptroller of public accounts (comptroller) (defendant) determined that due to TGS’s use of license agreements, the revenue was required to be allocated to the state in which the license was used, resulting in additional franchise-tax liability for TGS. TGS paid the additional taxes under protest and filed suit against the comptroller for a refund. The trial court granted summary judgment to the comptroller with respect to the disputed taxes. The appellate court affirmed, and TGS appealed.

Rule of Law

Issue

Holding and Reasoning (Medina, J.)

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