Department of Revenue v. Early & Daniel Co.

STERNBERG, Justice.

This litigation arose when the movant, the Department of Revenue, hereinafter referred to as Department, assessed additional corporate income tax due for 1972-1975 against respondent Early & Daniel Company, an Indiana corporation operating both within and outside Kentucky. It is the parent company of several domestic subsidiary corporations, and, most importantly, it is also the parent company of the Early & Daniel International Sales Company, Inc., hereinafter referred to as DISC. The DISC operates only in Ohio and is incorporated there. It has no employees and all but one…