Armour & Co. v. Department of Taxation

The Delaware corporation was a subsidiary of the Illinois corporation and on September 24, 1943, was merged into the appellant corporation which became liable as transferee for the income taxes of its subsidiary and stands in the position of the taxpayer so that no distinction will hereafter. be made between the two corporations. They will be referred to as the “taxpayer.”

At the time the tax was levied the taxpayer, was a foreign corporation doing business in Wisconsin as well as in many of the other states. The tax was figured by the Wisconsin authorities on a formula basis of apportionment…