Arizona Department of Revenue v. Transamerica Title Insurance

HAIRE, Judge.

The issues raised on this appeal relate to the propriety of certain federal income tax deductions taken by the appellee corporations on their state income tax returns for the years 1969 through 1972.

The appellees are subsidiaries of Transamerica Corporation within the meaning of federal income tax law. For the years in question, and for many years prior thereto, Transamerica Corporation and all of its subsidiaries (approximately 200 in number) had filed with the federal government a consolidated federal income tax return pursuant to 26 U.S.C. §§ 1501 — 4. At the end of every…