Personal Loan & Finance Co. of Capitol Hill v. Oklahoma Tax Commission

DAVISON, Justice.

This is an appeal by Personal Loan & Finance Co. of Capitol Hill (herein referred to as “taxpayer”) from an order of the Oklahoma Tax Commission assessing additional corporate franchise taxes for the tax year 1964-1965. The appeal presents the question of whether, in determining the amount of capital employed by the taxpayer in its business in Oklahoma, the taxpayer was entitled to deduct the amount of certain loans made to the taxpayer by its parent corporation.

The matter was tried before the Tax Commission upon a stipulation of facts. It was stipulated that the taxpayer is…