The Ohio Government Employees Credit Union (Union) was created by merging the Ohio Teachers Bank, the Ohio Transit Credit Association, and the Federal Government Workers Credit Bank. The stock issued by the merged entity is held by those having deposits in Union. Union believes that it is not subject to the Ohio franchise tax (an income tax) because immunity is implied under the Supremacy Clause of the U. S. Constitution. Union believes it is closely connected with the government and thus should be exempt from taxation. Is Union correct in its conclusion that it is not subject to the Ohio franchise tax?
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