California State Board of Equalization v. Renovizor's Inc. (In re Renovizor's Inc.)

GOULD, Circuit Judge.

Debtor, Renovizor’s, in bankruptcy court, objected to a claim filed by the California State Board of Equalization (“SBE”). In the trial held in bankruptcy court, SBE’s claim for civil tax fraud was upheld. On appeal, the United States District Court for the Northern District of California affirmed the bankruptcy court. Renovizor’s now appeals to our Court. The primary issue that we must decide is whether under California law civil tax fraud must be proved by clear and convincing evidence, as appellant Renovizor’s contends, or instead by a preponderance of the evidence,…