Schlumberger Technology Corp. v. Dubno
In Schlumberger Technology Corp. v. Dubno, 202 Conn. 412, 423-26, 521 A.2d 569 (1987), the Court discussed the applicability of 12-218 to service providers who use tangible personal property in the course of their commercial activities. After rejecting the proposition that all service providers automatically have their income apportioned to this state in accordance with the one factor formula contained in 12-218 (a), the court examined the relevant facts.
The taxpayer in Schlumberger provided wireline services to the oil and gas industry to determine the feasibility of producing oil or gas at a designated site. For that purpose, the taxpayer collected on-site data through the use of a specially designed sensory instrument. The data was then transmitted to a mobile laboratory where it was recorded in a form usable by the taxpayer's engineers. Id., at 426-27.