American Honda Motor Co., Inc. v. Larry Walther

Summary

The court held that judicial review of the agency’s interpretation of the Tax Procedure Act is de novo and that the definition of business income must be applied according to its plain language rather than strictly construed in limitation of taxation. It further held that American Honda’s proceeds from repeatedly selling environmental credits were business income under the transactional test because those sales occurred in the regular course of its business. The court therefore affirmed summary judgment for the Arkansas Department of Finance and Administration.