Alabama ALJ holds Sec. 199 deduction may be claimed on separate company basis

An I.R.C. Sec. 199 domestic production activities deduction may be computed and claimed on a separate company basis for purposes of Alabama income tax if an Alabama taxpayer has sufficient taxable income to claim the deduction, even where the deduction is limited for federal purposes because of a consolidated group's lack of taxable income, an Alabama Administrative Law Judge recently held. [GKN Westland Aerospace, Inc. v. Ala. Dept. of Rev., Admin. Law Div., Dkt. No. BIT. 10-988, 7/25/2011]