Legal Opinion
Container Corp. of America v. Franchise Tax Bd.
California Court of Appeal
Decided April 14, 1981No. Civ. 48990PublishedCited by 18 opinions
1Opinion of the Court
Opinion
CHRISTIAN, J.
Container Corporation of America appeals from a judgment denying partial refund of corporation franchise taxes paid for the income years 1963, 1964 and 1965. We affirm the judgment.
The question is whether, under stipulated facts, appellant was properly treated as deriving income from sources both within and outside California (Rev. & Tax. Code, § 25101) 1 on the basis that appellant and its foreign subsidiaries constituted a unitary enterprise.
Appellant, a Delaware corporation headquartered in Chicago, is engaged in the production and distribution of paperboard packaging…
2Cases cited35 opinions
- Complete Auto Transit, Inc. v. BradySupreme Court of the United States · 1977
- Select Base Materials, Inc. v. Board of EqualizationCalifornia Supreme Court · 1959
- Mobil Oil Corp. v. Commissioner of Taxes of Vt.Supreme Court of the United States · 1980
- Japan Line, Ltd. v. County of Los AngelesSupreme Court of the United States · 1979
- Moorman Manufacturing Co. v. BairSupreme Court of the United States · 1978
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3Cited by18 opinions
- Container Corp. of America v. Franchise Tax BoardSupreme Court of the United States · 1983
- California Union Insurance v. Landmark InsuranceCalifornia Court of Appeal · 1983
- Pioneer Container Corp. v. BeshearsSupreme Court of Kansas · 1984
- Mole-Richardson Co. v. Franchise Tax BoardCalifornia Court of Appeal · 1990
- State ex rel. Arizona Department of Revenue v. Talley Industries, Inc.Court of Appeals of Arizona · 1994
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