Indiana Department of State Revenue v. Colpaert Realty Corp.

The appellees are Indiana corporations having their offices in the same building in South Bend, Indiana. They are affiliates, but each keeps separate books and records. They are engaged in the business of buying real estate and subdividing, improving, leasing, mortgaging and selling the same.

The transactions in which they were engaged, and which are involved in this case, fall into three categories which have been designated, as B, C, and D. Class B transactions are those in which one of the appellees would erect a home on an unencumbered lot owned by it, and would then execute a note payable…