South Carolina Court of Appeals: Department bears burden of proof in alternative apportionment case

The South Carolina Court of Appeals held that the Department of Revenue, as the proponent of an alternative apportionment method, bore the burden of proving that the proposed method of alternative apportionment was reasonable and more appropriate than any competing methods. [CarMax Auto Superstores West Coast, Inc. v. South Carolina Department of Revenue, S.C. Ct. of Appeals, Opinion No. 4953, 3/14/12]