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

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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)]



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