Carpenter Technology Corp. v. Commissioner of Revenue Services

Opinion

The defendant, the commissioner of revenue services (commissioner), appealed from the judgment of the trial court sustaining an appeal by the plaintiff, Carpenter Technology Corporation, from the commissioner’s assessment of a corporate business tax deficiency. The trial court determined that the plaintiffs deductions of the interest it had paid on a loan made to it by a wholly owned subsidiary, Carpenter Investments, *456Inc., were appropriate because the subsidiary had economic substance and a business purpose, and because the relationship and transactions between the plaintiff and the…