Legal Opinion
Wilson v. Franchise Tax Board
California Court of Appeal
Decided December 13, 1993No. B073188PublishedCited by 4 opinions
1Opinion of the Court
Opinion
ORTEGA, J.
During 1984-1986, plaintiff Marc D. Wilson played quarterback for the Los Angeles Raiders. In the off-season during those years, Wilson lived in Washington State and thus was not a California resident for California income tax purposes. However, because Wilson’s income from his Raiders contract derived from a California source, he paid California income tax on a portion of his income for those years. Wilson’s income tax was based on a ratio, set out in defendant California Franchise Tax Board’s (the Board) administrative regulation (Audit Ruling AR-125.1) governing the…
2Cases cited5 opinions
- Peter Stemkowski v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1982
- Mole-Richardson Co. v. Franchise Tax BoardCalifornia Court of Appeal · 1990
- Jimmy Swaggart Ministries v. State Board of EqualizationCalifornia Court of Appeal · 1988
- American Hospital Supply Corp. v. State Board of EqualizationCalifornia Court of Appeal · 1985
- Newman v. Franchise Tax BoardCalifornia Court of Appeal · 1989
3Cited by4 opinions
- J. H. McKnight Ranch, Inc. v. Franchise Tax BoardCalifornia Court of Appeal · 2003
- Automotive Funding Group, Inc. v. GaramendiCalifornia Court of Appeal · 2003
- 2009 Metropoulos Family Trust v. California Franchise Tax BoardCalifornia Court of Appeal · 2022
- Beluca Ventures LLC v. Einride AktiebolagDistrict Court, N.D. California · 2023