© Piekwieck Collector, decided in November £7, California, case, no alleged ment went Apparentiy the taxpevyer did it felt that appeal brourkt action was hive been illegally for the The Pickwick a we siderable an to Dis not reeover assessec and appeal the wou 2 futile, extise taxes collected, Judg~ defendant, System, cision, 664, States owned the Welch, a United The alec v. Supp. by corporation, Since 21 Fed, 1957, doubt..because to Corporation all Corporation, hereinafter of of the corporation, facts are shall state stocx hereinafter necessary them the to an rather called Pickwick called the Stages the system. understanding of the fully, to a con+ quoting de-~ extent: "During all of this peried the chief officers and directors of both cempanies were identical, They issued consolidated belance sheets and operating statements, and filed consolidated income tax re turns with the federal covernment, "The corporation, as is alleged by the plaintiffs and admitted by the defendant, ecauired the stock of the system for the purpose of owning, cperseting, and controlling the motor transportation business of the system, so that, during the period ebove mentioned, the system was the instrumentality by which the corporation controlled that business, "In November, 1924, the corporation bus bodies for use Seventy-two bodies manufacture of by the system alone bodies were in fact subsidiary, * to the system at a figure end not so used for and were which and resale, consumed made included and began the consumption Said bus by that gold, and billed a profit to the