City National Corp. v. Franchise Tax Board

Opinion

WILLHITE, J.

Plaintiff and appellant City National Corporation (City National) appeals from an order dismissing its tax refund action after the trial court sustained without leave to amend the Franchise Tax Board’s (FTB) demurrer to City National’s amended complaint. FTB asserted in its demurrer that the trial court was without jurisdiction to hear City National’s claim for a refund because City National had not yet paid approximately $50 million in proposed assessments for the tax years at issue. City National contends it had paid all taxes that were due at the time it filed its refund…