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ARIZONA DEPT. OF REV. v. TRANSAMERICA TITLE

No. 14329-PR.

124 Ariz. 417 (1979)

604 P.2d 1128

ARIZONA DEPARTMENT OF REVENUE, Appellant, v. TRANSAMERICA TITLE INSURANCE COMPANY, a California Corporation; Transamerica Title Insurance Company of Arizona, an Arizona Corporation; and Transamerica Real Estate Tax Services, a California Corporation, Appellees.

Supreme Court of Arizona, In Banc.

December 11, 1979.

Attorney(s) appearing for the Case

Bruce E. Babbitt, The Former Atty. Gen., John A. LaSota, Jr., The Former Atty. Gen., Robert K. Corbin, Atty. Gen. by Frank L. Migray, Asst. Atty. Gen., Phoenix, for appellant.

Lewis & Roca by John P. Frank, David R. Frazer and John C. Mason, Phoenix, for appellees.

HOLOHAN, Justice.

Appellees here are three subsidiaries of Transamerica Corporation within the meaning of federal income tax laws. During the tax years in question, appellees joined with the parent corporation in the filing of consolidated federal income tax returns pursuant to 26 U.S.C. §§ 1501-4. The subsidiaries computed their separate federal income tax return as though they were not members of an affiliated...

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