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BARCLAY v. FIRST PARIS HOLDING CO.

No. 00-1128.

42 S.W.3d 496 (2001)

344 Ark. 711

Richard BARCLAY, Director, Arkansas Department of Finance and Administration v. FIRST PARIS HOLDING COMPANY and Subsidiary, First National Bank at Paris, Arkansas.

Supreme Court of Arkansas.

May 10, 2001.

Attorney(s) appearing for the Case

Mary Cameron, Little Rock, for appellant.

Jack, Lyon & Jones, P.A., by Eugene G. Sayre, Little Rock, for appellee.

Friday, Eldredge & Clark, LLP, by Walter M. Ebel, III and Joseph G. Nichols, Little Rock, amicus curie in support of appellees' position.

RAY THORNTON, Justice.

In 1979, the General Assembly adopted Act 708, allowing corporate members of an affiliated group that files a federal consolidated income tax return to file a consolidated Arkansas tax return. Following the adoption of Act 708, First Paris Holding Company [The Holding Company] was organized on March 27, 1980. At the time of its organization, the Holding Company owned eighty-six percent of the stock of First National Bank at Paris [First National...

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