A business conducted directly or indirectly by one corporation is unitary with that portion of a business conducted by another corporation through its direct or indirect interest in a partnership. Where the partner is an individual, the partner's share of income from the partnership will be taxed based on the individual income tax rate. Where the partner is a company, the partner's share of income from the.
Therefore, the ruling holds that if a partner is engaged in a unitary business with the partnership and holds a 25% interest, the partner and 25% of the partnership's income and factors are combined.
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