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Apportionment is accomplished by "multiplying a business's total margin by an apportionment factor." See Hallmark Mktg. Next, the entity's "taxable margin" is determined by apportioning the entity's "margin" to its business in Texas. 1012 (determination of cost of goods sold). §§ 171.101(a)(1)(B)(ii)(a)(1) (allowing taxable entity to subtract cost of goods sold). Pertinent to this appeal, Chapter 171 allows a taxable entity to subtract from its total revenue the cost of goods sold, sometimes referred to as the "COGS deduction." 1 See id.
SIRIUS XM STUDIOS LOCATION CODE
Tax Code §§ 171.101(a)(1) (determination of taxable entity's "margin").1011(c) (calculation of total revenue). Generally, a taxable entity's franchise-tax liability is calculated by first determining the entity's "margin," which is the lesser of 70% of the taxable entity's total revenue, or the entity's total revenue minus certain expenditures as allowed by Chapter 171. §§ 171.0001-.908, the franchise tax represents a tax on the value and privilege of doing business in Texas. Codified in Chapter 171 of the Tax Code, see id. Texas imposes a franchise tax on each taxable entity that does business in this state or that is chartered or organized in this state.
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SIRIUS XM STUDIOS LOCATION TRIAL
For the reasons that follow, we will reverse the trial court's judgment and render judgment in favor the Comptroller. Sirius XM, by cross-appeal, asserts that the trial court erred in not allowing it to include certain expenses in its cost-of-goods-sold deduction. Specifically, the Comptroller challenges certain findings of fact and conclusions of law made by the trial court concerning where Sirius XM's services were performed and how the fair value of those services in Texas should be calculated. On appeal, the Comptroller challenges the methodology employed by Sirius XM and adopted by the trial court to calculate that portion of Sirius XM's revenue attributable to its business in Texas in tax years 20. Following a bench trial, the trial court signed a judgment in favor of Sirius XM ordering the Comptroller to issue a refund. to recover franchise taxes paid under protest to Glenn Hegar, Comptroller of Public Accounts of the State of Texas. This appeal arises from a suit filed by Sirius XM Radio, Inc.