Montgomery Ward & Co. v. Franchise Tax Board

Opinion

SIMS, J.

Plaintiff taxpayer has appealed from a judgment which denied it recovery of a portion of its corporate franchise taxes (Rev. & Tax. Code, § 23151 1 ) assessed and paid for the taxpayer’s fiscal income years ending on January 31st in the years 1955 through 1960. The income upon which the tax for each year was based was that portion of the taxpayer’s total net income which the taxing authorities found to be derived from, or attributable to, sources within this state. 2 The taxpayer contends that respondent Franchise Tax Board erred in allocating its income in each of the years in…