Illinois – Pass-through miles included in transportation sales factor for pre-2008 tax years

For pre-2008 tax years, pass-through miles traveled in-state by an interstate trucking company without picking up or delivering goods should be included in the Illinois sales factor apportionment numerator. Although current law specifically includes gross receipts measured by pass-through miles in the apportionment numerator starting with the 2008 tax year, Illinois transportation companies may find this decision instructive to the extent pre-2008 years remain open.

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