Jim Beam Brands Co. v. Franchise Tax Board
California Court of Appeal
1Opinion of the Court
Opinion
SEPULVEDA, Acting P. J.
Jim Beam Brands Co. (Jim Beam) appeals from a grant of summary judgment in favor of the Franchise Tax Board (FTB) in a tax refund action. Jim Beam brought the action below after the State Board of Equalization (SEE) ruled that the gain from Jim Beam’s sale of the stock of a wholly-owned subsidiary constituted “ ‘[bjusiness income’ ” within the meaning of Revenue and Taxation Code section 25120, subdivision (a). The trial court sustained the SBE’s decision and held that income from the sale was apportionable to California. In this court, Jim Beam argues that the…
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