Greenwich Mills Co. v. State Tax Commission

OPINION OF THE COURT

Weiss, J.

Petitioner, a processor and wholesaler of coffee, timely filed separate corporation franchise tax returns for itself and each of three wholly owned subsidiaries for the years 1977, 1978 and 1979, and paid the tax shown on each report. On September 11, 1981, following a field audit, respondent State Tax Commission (hereinafter respondent) issued notices of deficiency for additional franchise taxes due each year plus interest on the basis that petitioner should have filed combined reports with its wholly owned subsidiaries. Prior to this determination, petitioner…