ASARCO, Inc. v. Idaho State Tax Comm'n

In ASARCO, Inc. v. Idaho State Tax Comm'n, 458 U.S. 307, 102 S. Ct. 3103, 73 L. Ed. 2d 787 (1982), the Supreme Court rejected a state's claim that dividend income received by a corporation on stock of partially owned subsidiaries was subject to tax as part of a unitary business. The taxpayer corporation bought a small percentage of goods from one subsidiary at market rates but did not exercise management control of the subsidiary. Id. at 322. The state argued that dividend income should be considered part of the unitary business if the shares of stock had been acquired for purposes relating to the taxpayer's business, but the Court declined to find integration on this ground. Id. at 326.