Respondent State Tax Commission (commission) made the following pertinent findings: Petitioner Coleco Industries, Inc. (Coleco), is a Connecticut corporation engaged in the manufacture and sale of recreational products. In 1969, it created Coleco North Corporation (Coleco North) as a wholly owned subsidiary. During 1970 and 1971, Coleco North bought swimming pools and related products from Coleco and sold them to Coleco Canada, a wholly owned Canadian subsidiary. With the...
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