Chilivis v. Cleveland Electric Co. of Georgia, Inc.

Shulman, Judge.

Appellee, Cleveland Electric Co. of Georgia, Inc., is an electrical contracting company and a taxpayer. The state revenue commissioner, appellant in this action, made an assessment against appellee for taxes allegedly owing as a result of a stock redemption by and liquidation of CEBM, Ltd., a foreign corporation. CEBM, Ltd. performed electrical contracting in the Bahamas. Ninety-six per cent of CEBM’s stock was owned by Cleveland Management Corp., a wholly owned subsidiary of Cleveland Electric Co. of Georgia, Inc. CEBM was not an extension of Cleveland Electric Co. of Georgia…