Legal Opinion
Hugo Neu-Proler International Sales Corp. v. Franchise Tax Board
California Court of Appeal
Decided October 5, 1987No. B022691PublishedCited by 4 opinions
1Opinion of the Court
Opinion
ROTH, P. J.
The Franchise Tax Board (Board) appeals from the judgment in favor of Hugo Neu-Proler International Sales Corporation (Hugo Neu-Proler ISC) in the corporation’s action for a refund of taxes paid. The basic question is whether there is “unity of ownership” when two corporations are equal partners in a company which owns 100 percent of a third corporation. We affirm.
The parties have stipulated to the relevant facts. Hugo Neu & Sons, Inc., is a corporation whose principal office is in New York. It is an international marketer of metals. Proler International Corporation is a…
2Cases cited6 opinions
- Culligan Water Conditioning of Bellflower, Inc. v. State Board of EqualizationCalifornia Supreme Court · 1976
- Edison California Stores, Inc. v. McColganCalifornia Supreme Court · 1947
- Butler Brothers v. McColganCalifornia Supreme Court · 1941
- Anaconda Co. v. Franchise Tax BoardCalifornia Court of Appeal · 1982
- B. Forman Company, Inc. v. Commissioner of Internal Revenue, McCurdy & Company, Inc. v. Commissioner of Internal Revenue, B. Forman Company, Inc. v. Commissioner of Internal Revenue, McCurdy & Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1972
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3Cited by4 opinions
- True v. HeitkampNorth Dakota Supreme Court · 1991
- Brown v. Advantage Engineering, Inc.District Court, N.D. Georgia · 1990
- In Re the Appeal of Panhandle Eastern Pipe Line Co.Supreme Court of Kansas · 2002
- True v. HeitkampNorth Dakota Supreme Court · 1991