"interlocking directorate and officers, the 100 per cent, control by the parent of the subsidiary, and the use of consolidated balance sheets, all show that the two companies were to ail intents and purposes one oper~ ating unit, among They others, tion vs Les 0 » hs Hh. Miller cite the Lewellyn, 248 lid, & in support U. 8, following Avlats Ra B97 of cases: Tl, s 89 their position, Ct. 35, Gulf &. Southern O11 Corpora- 63 racitic CO. Ve Lowe, 247 U. 8. 680, 38 &S, Ct, 540, 548, 62 L. Ed, 1142, 6 AF.T.R, 2988; Wenben Estate, Ine., Vv, Hewlett, 195 Cal, 675, 676, at page 696, 8227 P, 7233 Industries Company A.) 61 F. @d 412, 11 A.PLT.R,. The of the the court cases bus Commissioner bodies and confirmed elited by the "However, (C.C, found that there had been a sale assessed and collected the tex and action, After distinguishing court continued: he his v. Commissioner 951," plaintiff, the these cannot cases be rerarded the ag laying down any general rule, authorising disregard of corporate entity in respect of taxation —— rather ag instances when the courtiooked through mere form and regarded substance, HBurnetv. Commonwealth improvement Company, supra. The doctrine of corpo- rate entityis one of substance anc validity; it should,be ignored with eaution, and only when. the circumstances clearly justify it. The theory of the alter ego has been adopted by the courts toe prevent injustice, in those cases where the fiction of a corporate entity has been used as a subterfuge to defeat public convenience or to perpetuate a wrongs 1% should never be invoked to work an injustice, or to give an unfair advantage, Corning Glass Works v, Comiissioner, 2 B.T,A. 77L; Corning Glass Yorks v. Lucas, 59 App, D, C, i168, 67 F, &d 798, $8 ALR, 706; i0,, 281 U, &, Tey 50°. Ct, 648, 7é Ly Edy 1155; Ola Colony Trust Co,, Exeeutors, v. Commissioner (C,.C.A.) 69 FPF. 24 G90, 12 A.P.T.R, 7613 hee Co, V. Helvering, 282 U, S&S, 455, 78 le Ed, 1648, 15.A.F.T.R. 1180, "A Revenue eareful Acts of examination 1924 and of 1926, thse sec which New Colonial 54 8. Ct, ons Lon ha ve bee 788,