Steuer v. Franchise Tax Bd.

Filed 6/29/20 CERTIFIED FOR PUBLICATION IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA FIRST APPELLATE DISTRICT DIVISION THREE ALAN STEUER, as Trustee, etc., et al., Plaintiffs and Respondents, A154691 v. FRANCHISE TAX BOARD, (City & County of San Francisco Defendant and Appellant. Super. Ct. No. CGC-16-556126) Franchise Tax Board (FTB) appeals from a summary judgment order holding (1) a trust’s income, even if entirely derived from California sources, is only taxable under residence-based taxation; and (2) the sole beneficiary of the Paula Trust was a contingent beneficiary. The law is…