People v. Santa Fe Federal Savings & Loan Ass'n

THE COURT.

Following the decision adverse to the respondent by the District Court of Appeal, the taxpayer’s petition for a hearing by this court was granted for the principal purpose of considering the direction to the superior court to enter judgment for the state. Subsequently, the attorney general rested his case upon the sole issue as to whether under the Bank and Corporation Franchise Tax Act, as it read in 1939, a taxpayer was entitled to file a protest with and have a hearing before the Franchise Tax Commissioner as a condition precedent to the levy of an assessment levied upon the…