...has appellant undertaken to prove that the amount of its tax liability as determined by Vermont is "out of all appropriate proportion to the business transacted by the appellant in that State." Hans Rees' Sons v. North Carolina ex rel. Maxwell, 283 US 123, 135 (1931)." What appellant does seek...

...the appellant's business for the years in question operated unreasonably and arbitrary in attributing to North Carolina a percentage of income out of all...business transacted by the appellant in that State. A tax levied by North Carolina upon the net income of interstate railways doing business in North Carolina...

...proving that the statutory method as applied to it, "operated unreasonably and arbitraiily in attributing to North Carolina a percentage of income out of all...business transacted by the appellant in that state." l? With the triumvirate of Underwood Typewriter Co., Bass, KaifUjf if> Gretton, and Hans Ret*' Sons,...

...appellant's business for the years in question operated unreasonably and arbitrarily, in attributing to North Carolina a percentage of income out of all...appropriate proportion to the business transacted by appellant in that State."22 Thus, because of the procedural guise in which the case came to the Supreme...

...756 (1967) ; Norfolk & Western R. Co. v. State Tax Comm'n, 390 US 317, 325 (1968). The tax cannot be "out of all appropriate proportion to the business transacted by the appellant in that State." Hans Rees' Sons v. North Carolina ex rel. Maxwell, supra, at 135. The nexus is established if the corporation...

...eighty per cent of the income. The Court held the assessments invalid as attributing to the taxing state a percentage of income "out of all appropriate proportion" to the business transacted in the state. It was careful to point out, however, the difficulty of making an exact apportionment...