CSX Wins Recalculation of Ohio Commercial Activity Tax Liability

Jan. 2, 2026, 10:02 PM UTC

CSX Transportation Inc. convinced the Ohio Board of Tax Appeals on Friday that the state used the wrong methodology to determine the proportion of its sales taxable there to calculate a $9 million commercial activity tax bill.

Ohio Tax Commissioner Patricia Harris inappropriately applied a statute for situsing the sale of transportation services “by a motor carrier” to the railroad’s activities from 2012-2016, the board ruled. “Receipts from the sale of transportation services by a vehicle, locomotive, or car operated exclusively on a rail or rails” aren’t subject to that provision after a 2012 amendment, the board said.

The ...

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