Gable Industries, Inc. v. Blackmon

Ingram, Justice.

Certiorari was granted in this case primarily to review the decision of the Court of Appeals regarding the authority of the State Revenue Commissioner to grant permission to a taxpayer to file consolidated corporate income tax returns and to review the effect of a subsequent retroactive revocation of that permission by a successor commissioner after reliance thereon by the taxpayer.

This corporate taxpayer sought and received tentative permission in 1964 from the State Revenue Commissioner to file consolidated Georgia income tax returns with its wholly owned subsidiary…