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Ohio Board of Tax Appeals provides guidance on determining ultimate destination rule for CAT purposes

The Ohio Board of Tax Appeals (BTA) held that a taxpayer’s sales were properly sitused to Ohio for purposes of the Commercial Activity Tax because the “ultimate destination” of the goods sold by the taxpayer, after all transportation had been completed, was Ohio. The BTA’s determination of the “ultimate destination” of the goods rested on customer orders and bills of lading, all of which reflected “ship to” addresses in Ohio. The BTA noted that the taxpayer’s failure to produce any evidence that the goods may have subsequently been removed from Ohio foreclosed any argument that the “ultimate destination” was outside Ohio.