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DEPT. OF REVENUE v. EARLY & DANIEL CO., INC.

628 S.W.2d 630 (1982)

DEPARTMENT OF REVENUE, Commonwealth of Kentucky, Movant, v. The EARLY & DANIEL COMPANY, INC., Respondent.

Supreme Court of Kentucky.

March 9, 1982.

Attorney(s) appearing for the Case

Ben B. Fowler, Bruce Clark, Stites, McElwain & Fowler, Frankfort, Stephen M. Nechemias, Scott A. Siebels, Taft, Stettinius & Hollister, Cincinnati, Ohio, for respondent.

Richard F. Newell, George W. Craven, Gary A. Tabler, Ogden, Robertson & Marshall, Rucker Todd, Joseph L. T. Ardery, Brown, Todd & Heyburn, Louisville, William D. Dexter, Gen. Counsel, Multistate Tax Com'n, Olympia, Wash., James K. Caudill, Tax Counsel Batus, Inc., Louisville, for amici curiae.

Steven Beshear, Atty. Gen., Alex W. Rose, Asst. Atty. Gen., Cathy Cravens Snell, Legal Services Div., Dept. of Revenue, Frankfort, for movant.

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...

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