Fedders Corp. v. State Tax Commission

Petitioner, a New York corporation organized in . 1913, manufactures appliances which it sells directly to independent distributors who, in turn, resell them to local retailers. The retailers frequently require inventory financing in order to carry petitioner’s and other manufacturers’ products and regularly enter into so-called “floor-planning agreements” with .banks or independent finance companies. In 1959, Fedders Financial Corporation (FFC) was organized as a wholly-owned domestic subsidiary of petitioner and is such a financing institution.

Since .FF'C’s incorporation and continuously…