Cable One, Inc. v. Idaho State Tax CommissionAnnotate this Case
Cable One, Inc., is a Delaware corporation headquartered in Phoenix, Arizona. In 2005, Cable One received business income from four types of activities in Idaho: cable television services, internet access services, advertising services, and cable modem leasing. In its Idaho income tax return for that year, it included revenues earned from all of those activities except revenues from providing internet access services to Idaho customers. It excluded those revenues on the ground that providing such services to customers in Idaho constituted Arizona sales, although it also excluded such revenues from its 2005 Arizona income tax return on the ground that they came from Idaho sales. In 2008, the Idaho Tax Commission issued a notice of deficiency determination asserting a tax and interest deficiency on Cable One for the 2005 tax year. Cable One petitioned for redetermination, which the Tax Commission denied. Cable One then filed a complaint in the district court, which tried the matter de novo, and ruled in favor of the Tax Commission. Cable One then appealed to the Idaho Supreme Court. Finding no reversible error, the Supreme Court affirmed the district court.