Bumble Bee Seafoods, Inc. v. State Tax Commission

Edward H. Howell, Judge.

Pursuant to OES 317.070(2) (b) plaintiff claimed a personal property tax offset against its corporate excise tax. Defendant disallowed the offset.

Plaintiff was incorporated on May 24, 1961, and on May 31, 1961, exchanged all of its stock for all of the assets and liabilities of Columbia Eiver Packers Association (hereinafter referred to as CEPA). On the ■same day, immediately subsequent to the exchange between plaintiff and CEPA, the ■shareholders in the latter corporation exchanged all of their stock for ■stock in Castle & Cooke, Inc., a Hawaiian corporation,…