Freeport Texas Co. v. Bowers

AUGUSTUS N. HAND, Circuit Judge.

The plaintiff, which is the parent of various affiliated corporations, sued: (1) to recover a deficiency assessment of income taxes amounting to $1,260,466.18 because it was laid entirely against the parent company, which had no income, instead of being apportioned on the basis of net income assignable to each of the affiliates; (2) to recover $347,436.36 because, even if the income taxes of the affiliates were properly laid against the parent company, the Bryan Mound properties belonging to the Free-port Sulphur Company, a member of the consolidated group,…