Legal Opinion
Heller v. Franchise Tax Board
California Court of Appeal
Decided January 25, 1994No. C015814PublishedCited by 7 opinions
1Opinion of the Court
Opinion
NICHOLSON, J.
Michael and Sylvia Heller appeal from the trial court’s grant of summary judgment in favor of the Franchise Tax Board. (Code Civ. Proc., § 437c.) Although this appeal involves the tax liability of the Hellers as individuals, its resolution turns on whether the accumulated adjustments account (AAA) of a California S corporation is increased for interest income earned on United States Treasury Bills, and this is the only issue presented on appeal. We reverse.
Factual and Procedural Background
The Franchise Tax Board (the Board) audited the Hellers and Tecon Corporation, a…
2Cases cited5 opinions
- Robert Fehlhaber v. Commissioner, Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 1992
- John E. Byrne v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1966
- Charles D. Beard, Jr. Mary Sue Beard v. United States of America, John G. Beard Louise H. Beard v. United StatesCourt of Appeals for the Eleventh Circuit · 1993
- Tenneco West, Inc. v. Franchise Tax BoardCalifornia Court of Appeal · 1991
- W. Harley Huxford and Rae Huxford v. United States of America, Walter D. Taylor and Carolyn H. Taylor v. United StatesCourt of Appeals for the Fifth Circuit · 1971
3Cited by7 opinions
- Tarrant v. Department of TaxesSupreme Court of Vermont · 1999
- Morton v. Morton (In re Morton), California Court of Appeal, 5th District2018
- Valentino v. Franchise Tax BoardCalifornia Court of Appeal · 2001
- Handlery Hotels, Inc. v. Franchise Tax BoardCalifornia Court of Appeal · 1995
- Sprint Communications Co. v. State Board of EqualizationCalifornia Court of Appeal · 1995
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