Citicorp North America, Inc. v. Franchise Tax Board

Opinion

MARCHIANO, J.

Citicorp North America, Inc. (Citicorp) and its affiliates appeal from a decision of the superior court in favor of the Franchise Tax Board (FTB) in this action for refund of corporate franchise taxes. We affirm the trial court’s judgment. The FTB properly included the California sales of Citicorp’s Citibank (South Dakota), a member of the unitary corporate group, in calculating the amount of income apportionable to California operations under the rule in effect at the time Citicorp filed its amended returns. We also reject Citicorp’s contention that the gain on sales of…