THIGPEN, Judge.
Delhaize America, Inc., ("Plaintiff") filed a tax refund action seeking approximately $10 million in corporate income taxes and penalties from the State of North Carolina. The trial court entered an order on summary judgment upholding the decision of the North Carolina Department of Revenue ("Defendant") to combine Plaintiff and Plaintiff's Florida-based subsidiary for purposes of taxation, but invalidating the penalty imposed by Defendant. Plaintiff...
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