Yamaha Corp. of America v. State Board of Equalization

Opinion

BROWN, J.

For more than 40 years, the State Board of Equalization (Board) has made available for publication as the Business Taxes Law Guide summaries of opinions by its attorneys of the business tax effects of a wide range of transactions. Known as “annotations,” the summaries are prompted by actual requests for legal opinions by the Board, its field auditors, and businesses subject to statutes within its jurisdiction. The annotations are *5brief statements—often only a sentence or two—purporting to state definitively the tax consequences of specific hypothetical business transactions.1…