Willamette Industries v. Franchise Tax Board

Opinion

REYNOSO, J.

We are called upon to interpret a statute increasing a franchise tax rate in two particulars. First, when was the effective date of the change to the higher rate? Second, did the change immediately cover only “calendar” or “fiscal” years (both 12 months) or also include a shorter period, here four months? As we explain below, we conclude that the effective date predated the four-month period in question, and the statute covers a term of less than a year, as well as the ordinary fiscal and calendar years.

*530Plaintiff Willamette Industries appeals from a judgment of the…