Honolulu Oil Corp. v. Franchise Tax Bd

In Honolulu Oil Corp. v. Franchise Tax Bd. (1963) 60 Cal.2d 417, the court rejected a contention that control by central management and centralized performance of service functions are insufficient alone to support a conclusion of a unitary operation ( id., at p. 423), and determined that "the mere fact that production and sale . . . are a local operation does not transform that operation to something distinct and apart." ( Id., at p. 424.)