Legal Opinion
Franchise Tax Board v. Superior Court
California Court of Appeal
Decided November 20, 2013No. A134734; A134735PublishedCited by 4 opinions
1Opinion of the Court
Opinion
RICHMAN, J.
The Franchise Tax Board (FTB or the Board) sought penalties against real parties in interest Quellos Group, LLC, and Quellos Financial Advisors, LLC (collectively Quellos), for allegedly promoting an abusive tax shelter to a California taxpayer in 2001. Respondent Superior Court of San Francisco ruled for Quellos, and the Board seeks review of a single issue: whether a 2003 amendment to Revenue and Taxation Code 1 section 19177 increasing the penalty for promoting an abusive tax shelter from $1,000 to 50 percent of the gross income received can be retroactively applied. The…
2Cases cited40 opinions
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- National Federation of Independent Business v. SebeliusSupreme Court of the United States · 2012
- In Re Tobacco II CasesCalifornia Supreme Court · 2009
- Samantar v. YousufSupreme Court of the United States · 2010
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3Cited by4 opinions
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