VVF Intervest, L.L.C. v. Harris

Summary

The court held that VVF's gross receipts from sales to HRB were properly sitused to Ohio because HRB received the goods at an Ohio distribution center, and HRB's later resales did not alter the situs of VVF's sales. The court also dismissed VVF's alternative statutory argument for lack of preservation and rejected its due-process, Commerce Clause, and equal-protection challenges. The Board of Tax Appeals' decision was therefore reversed.