Great-West Life Assurance Co. v. State Board of Equalization

Opinion

NOTT, J.

The Great-West Life Assurance Company appeals from the judgment entered against it in two consolidated actions brought to recover refunds of taxes paid to respondent, the State Board of Equalization (the Board). (Rev. & Tax. Code, § 13103.) We modify and affirm the judgment.

Factual and Procedural Background(1) Introduction and Procedural History

Each insurer in California is required to pay a tax on the gross premiums it receives each year. (Cal. Const., art. XIII, § 28 [former § 14-4/5]; Rev. & Tax. Code, §§ 12221, 12202, 12202.1.) Appellant is an insurance company which…