First National Bank v. Kansas Department of Revenue

Brazil, J.:

The First National Bank of Manhattan, Kansas, (First Bank) appeals from a Board of Tax Appeals (BOTA) order finding First Bank must pay a privilege tax based only on First Bank’s taxable income and that First Bank and First Manhattan Bancorporation (Bancorp), a holding company which owns a majority of First Bank’s stock, may not file a consolidated tax return for purposes of determining Kansas income tax liability. First Bank also appeals the BOTA’s finding that Bancorp and First Bank may not be treated as a unitary business for tax purposes. We affirm.

First Bank is a nationally…