Jones Apparel Group/Nine West Holdings

Summary

The Ohio Supreme Court affirmed the Board of Tax Appeals’ denial of Jones Apparel’s commercial‑activity‑tax refund, holding that the corporation failed to meet its evidentiary burden to prove the amount of gross receipts that should be excluded. The Court also rejected the tax commissioner’s argument that R.C. 5751.033(E) imposes a contemporaneous‑knowledge requirement and found Jones Apparel lacked standing to raise a proposition of law it was not aggrieved by.