Milwaukee Refrigerator Transit Co. United States v. Milwaukee Refrigerator Transit Co. Enverga Law School Corporation Law SC Division. Supreme Court on High Court's Suryanelli Judgment. Supreme Court on High Court's Suryanelli Judgment. Prem Panicker. Judiciary of the Republic of Trinidad and Tobago Annual Report 2010-2011 (1)The Milwaukee Refrigerator rule focused on the harm to the plaintiff. Some courts did not like this because they felt it too vague. They began to focus on the relationship between the owners of the corporation and the corporation itself. Various tests and theories emerged. •Alter ego •Instrumentality •Sham

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