Legal Opinion
A. M. Castle & Co. v. Franchise Tax Board
California Court of Appeal
Decided July 25, 1995No. A064957PublishedCited by 6 opinions
1Opinion of the Court
Opinion
PARRILLI, J.
A. M. Castle & Co. (Castle) appeals after the trial court denied its claim for a refund of corporate franchise taxes for the tax years 1975 through 1978. The court concluded Castle was unitary with its wholly owned subsidiary, Hy-Alloy Steels Co. (Hy-Alloy), and found that California could therefore include Hy-Alloy’s income in its tax calculation, even though Hy-Alloy did not directly do business in California. We affirm.
I. Facts
California imposes a franchise tax on corporations doing business within this state. The tax depends on the corporation’s net income attributable…
2Cases cited16 opinions
- Container Corp. of America v. Franchise Tax BoardSupreme Court of the United States · 1983
- Edison California Stores, Inc. v. McColganCalifornia Supreme Court · 1947
- Butler Brothers v. McColganCalifornia Supreme Court · 1941
- Superior Oil Co. v. Franchise Tax BoardCalifornia Supreme Court · 1963
- Honolulu Oil Corp. v. Franchise Tax BoardCalifornia Supreme Court · 1963
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3Cited by6 opinions
- Building Permit Consultants, Inc. v. MazurCalifornia Court of Appeal · 2004
- Louis Dreyfus Corp. v. HuddlestonCourt of Appeals of Tennessee · 1996
- HOECHST CELANESE v. Franchise Tax Bd.California Court of Appeal · 2000
- AIG Insurance Management Services, Inc. v. Vermont Department of TaxesSupreme Court of Vermont · 2015
- Garcia-Rojas v. Franchise Tax BoardCalifornia Court of Appeal · 2026
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