Gray v. Franchise Tax Board

Opinion

GRIGNON, J.

—The sole issue on appeal is whether plaintiffs and respondents Harry J. Gray and Helen Gray (taxpayers), who are Connecticut residents, are entitled to a credit against their 1979 and 1980 California nonresident personal income taxes for taxes which were paid to the State of Connecticut on California-source capital gains. We conclude that taxpayers are entitled to such a credit and affirm.

Facts

Taxpayers and defendant and appellant Franchise Tax Board (Board) stipulated in writing to the following facts:

“1. During the years 1979 and 1980, [taxpayers] were residents of the…