International Paper Co. v. Director, Division of Taxation

Plaintiff International Paper Company (IP) brought this action in the Tax Court challenging the denial by defendant Director, Division of Taxation of its claims for refunds of corporation business tax paid by it for tax years 1981 and 1982. More particularly, it challenged the tax imposed on the capital gain and interest income it realized on the sale of its stock in Canadian International Paper Company (CIP) and the tax imposed on the capital gain it realized on the sale of its stock in C.R. Bard, Inc. (Bard). CIP was a wholly-owned subsidiary of IP. IP, however, owned only 14.4% of Bard’s…