Aristar, Inc. v. United States

Plaintiff (taxpayer) in this case is a holding company with approximately 450 subsidiaries engaged in the consumer finance business in some 30 states. Plaintiff, itself, is not actively engaged in business and during the fiscal years in question (1964,1965, and 1966) had only a minor amount of assets besides its advances to and equity investments in its subsidiaries. The consumer finance operations of the subsidiaries consisted primarily of making installment *618loans to individual borrowers in amounts ranging from $300 to $2,500.

Plaintiff operated by borrowing money and relending it to its…