An Indiana taxpayer claimed net operation loss deductions (“NOLs”) on its adjusted gross income. The NOLs were acquired by the taxpayer as part of a corporate acquisition. The Indiana Department of Revenue did not dispute that the taxpayer was entitled to the NOLs, but limited the NOLs by an “asset ratio” based on the assets of the member of the acquired group that was doing business in the state. The Department, in reviewing the audit adjustment, held that the application of the asset ratio was without any authority. Therefore, the Department failed to meet its burden to support the additional limitation to the taxpayer’s NOLs and the audit adjustment was reversed.