Texas Supreme Court May 27, 2011, 08-1056 (TGS-NOPEC GEOPHYSICAL CO. v. Combs)

Justice MEDINA

delivered the opinion of the Court.

This appeal arises from a franchise tax dispute involving the apportionment of receipts from the licensing of geophysical and seismic data to customers in Texas. The taxpayer complains that the Comptroller has mischaracterized these receipts as Texas business and thereby has erroneously increased its franchise tax burden.