payroll, and sales attributable to in-state value under the Uniform Division of Income for Tax Purposes Act, thus lowering the UDITPA fractional multiplier used against taxpayer’s total income and thereby its state taxable income base.”). 25 . While the tax at issue in NCR Corp. was a corporate income tax, similar overstatement of the contribution of subsidiaries to the parent company may occur in the value tax context due to the inclusion of full subsidiary property, payroll, and sales factors in apportionment in circumstances in which the capitalized dividends taken into account in determining the tax base represent merely a portion of the net income or profits of subsidiaries, some of which is retained. 26 . Accord Container Corp., 463 U.S. at 169 n. 7, 103 S.Ct. at 2942 n. 7 (<HOLDING>); Walter Hellerstein, State Taxation of
recognizing as a substantial factor that the state in that case included dividends from the subsidiaries to the parent in its calculation of the parents apportionable taxable income but did not include the underlying income of the subsidiaries themselves holding that trial judge has discretion to not include bonuses as part of gross income if he or she determines that the bonus income is not dependable or would place a hardship on a parent holding that gross income can include interest or dividends accruing to fathers ira holding that failure to report a change in federal taxable income as required by state law excepted state tax liability from discharge holding that a claimant is required to establish a physical inability to follow any occupation from which he can earn a reasonably substantial income rising to the dignity of an income or livelihood although the income may not be as much as was earned prior to the disability