{¶ 1} Appellant American Home Products Corporation, n.k.a. Wyeth ("AHP"), appeals from a decision of the Ohio Board of Tax Appeals ("BTA"), which sustained a determination by appellee Roger W. Tracy, the Ohio Tax Commissioner, denying part of a corporate franchise tax refund claimed by one of AHP's subsidiaries, A.H. Robins Company, Inc. ("Robins II"). Robins II is the successor pursuant to bankruptcy...
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