Loomis v. State of California

Subdivision (c) of section 15110 of the Revenue and Taxation Code of California has never been judicially construed, although it has been a law (in its present habitation in the Revenue and Taxation Code and in its earlier domicile, the Gift Tax Act [Stats. 1939, ch. 652, p. 2082]) since 1939, and it is our present task to give the initial interpretation.

Subdivision (e) defines Class A donee as: “A donee to whom the donor for not less than 10 continuous years prior to the transfer stood in the mutually acknowledged relationship of a parent, if the relationship commenced on or before the…