F.W. WOOLWORTH CO. v. FRANCHISE TAX BD.

Docket No. A017684.

160 Cal.App.3d 1154 (1984)

207 Cal. Rptr. 149

F.W. WOOLWORTH CO., Plaintiff and Appellant, v. FRANCHISE TAX BOARD, Defendant and Respondent.

Court of Appeals of California, First District, Division Three.

October 18, 1984.


Attorney(s) appearing for the Case

COUNSEL

McCutchen, Doyle, Brown & Enersen, John B. Lowry, John R. Reese, Diane A. Konigsberg and Michael D. Bray for Plaintiff and Appellant.

John K. Van de Kamp, Attorney General, and Timothy G. Laddish, Deputy Attorney General, for Defendant and Respondent.


OPINION

SCOTT, J.

This appeal poses the issue of whether F.W. Woolworth Co. (Woolworth U.S.), a New York corporation doing business in California, was engaged in a unitary business with F.W. Woolworth Co., Limited (Woolworth Canada), a Canadian corporation, during the years 1961 through 1964. The case has its genesis in tax assessments made by the State of California Franchise Tax...

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