Dow Chemical Co. v. Commissioner of Revenue

The Dow Chemical Company, a Delaware corporation conducting business in the Commonwealth, contends that the Commissioner of Revenue, in calculating the taxable net income of the corporation for the year 1969 for purposes of the corporate excise, unlawfully included therein certain items deriving from income of controlled foreign 1 subsidiaries. This resulted in an assessment of additional tax which Dow seeks to recover by the present appeal.

I. Statement. The facts are stipulated. Dow, with its principal place of business in Midland, Michigan, is engaged in the manufacture and sale of…