Illinois apportionment factor includes revenue from transported gas that neither originates nor terminates in Illinois, for pre-2008 tax years

Taxpayers transporting natural gas by pipeline were required to include in their apportionment factors those miles of gas transported through Illinois that neither originated nor terminated in Illinois. A subsequent law change specifically including such "flow-through" miles in the apportionment calculation had no effect on the years at issue. An Illinois appellate court held that including "flow-through" miles was consistent with statutory construction and legislative intent. [Panhandle Eastern Pipeline Co. v. Hamer, No. 1-11-3559, Ill. App. Ct. (12/7/12)]