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Taxpayers and taxing jurisdictions are, by definition and motivation, opposing forces and, therefore, in continual conflict. Taxpayers strive to minimize their tax liabilities while taxing jurisdictions seek ways to maximize their tax revenues. The unitary tax apportionment method was conceived by taxing jurisdictions as a method to prevent taxpayers from avoiding their fair share of the tax burden. The method evolved from a fairly insignificant procedure for the assessment of local property taxes to a very controversial means of apportioning the worldwide income of multinational corporate groups. Taxpayers have challenged the unitary tax apportionment method by utilizing economic sanctions, the legal system and the political process. This paper traces the effect of taxpayers' judicial, political and economic actions on the evolution of the unitary tax apportionment method. The study demonstrates that although taxpayers challenged this expansion numerous times in the courts and through the political process, it was not until taxpayers used economic sanctions that the states began to restrict the reach of the unitary method. Public law, case law, position statements, interviews and journal and newspaper articles provided the data for this study.



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