Central Cooling & Supply Co. v. Director of Revenue

HIGGINS, Judge.

Central Cooling & Supply Company seeks reversal of a decision of the Administrative Hearing Commission which affirmed the Director’s assessment of sales and use tax against Central on transfers of goods between it and its parent, Johnson Furnace Company. The decision rests on a determination that Central and Johnson are separate corporate entities and that the transfers of goods between them constituted taxable sales. Central contends they are not separate entities because Central is “a nominee or business conduit of Johnson.” See Blackwell Printing Co. v. Blackwell-Wielandy…