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Fargo v. Commissioner of Internal Revenue
IRS did not abuse discretion by rejecting taxpayers' offer to pay $7,500 in compromise of $104,000 interest owed on income tax liabilities.
Taxation Jul. 11, 2006
Marion Drive v. Saladino (Gibson)
Bond owner is lienholder of record prior to recordation of tax deed with priority over lender's subsequently recorded deed of trust.
Taxation Jul. 10, 2006
Commissioner of Internal Revenue v. Ewing
Tax court did not have jurisdiction over petition for review because no deficiency had been asserted.
Taxation Jun. 26, 2006
Ordlock v. Franchise Tax Board
Taxpayers need not report IRS correction for year for which Franchise Tax Board is time-barred from assessing additional income taxes.
Taxation Jun. 20, 2006
Ordlock v. Franchise Tax Board
Taxpayers need not report IRS correction for year for which Franchise Tax Board is time-barred from assessing additional income taxes.
Taxation Jun. 20, 2006
Gorospe v. Commissioner of Internal Revenue
Tax court's jurisdiction over appeal from collection due process determinations is limited to issues where court has jurisdiction over underlying tax liability.
Taxation Jun. 20, 2006
Jibilian v. Franchise Tax Board
In tax refund case, plaintiffs' claim that wages from private employment within United States are not taxable income is without merit.
Taxation Jun. 15, 2006
Mayer v. L & B Real Estate
Court's quieting title in favor of plaintiffs is not proper where quiet title action was filed after limitations period expired.
Taxation Jun. 15, 2006
Johnson v. Commissioner of Internal Revenue
Amendment to applicable Internal Revenue Code section did not apply to party's lump sum tax deduction for alimony.
Taxation Jun. 14, 2006
Slocum v. State Board of Equalization
Expansion of calamity reassessment relief beyond requirement of 'direct physicality' embedded in Constitution and Revenue and Taxation Code Section 170(a)(2) is invalid.
Taxation Mar. 20, 2006
Agnew v. State Board of Equalization
Taxpayer was entitled to award of costs as 'prevailing party' under Code of Civil Procedure Section 1032.
Taxation Feb. 21, 2006
Neilson v. City of California City
California Constitution does not prohibit city's special flat-rate parcel tax on mere ownership of real property.
Taxation Jan. 31, 2006
Jim Beam Brands Co. v. Franchise Tax Board
Distributor's income from sale of subsidiary qualified as 'business income' under Revenue and Taxation Code.
Taxation Jan. 24, 2006
Charlotte's Office Boutique Inc. v. Commissioner of Internal Revenue
Tax court's jurisdiction may extend to making determinations concerning proper amount of employment tax.
Taxation Dec. 19, 2005
Stead v. United States
Taxpayer bears loss when funds disappear from banking account that had been levied by IRS.
Taxation Nov. 15, 2005
Silicon Valley Taxpayers Assoc. Inc. v. Santa Clara County Open Space Authority
Proposition 218 does not prohibit use of assessment to fund county's future acquisitions of properties.
Taxation Nov. 4, 2005
Milhous v. Franchise Tax Board
Tax assessment on income plaintiffs received from covenant in contract was not enforceable in California.
Taxation Nov. 3, 2005
IBM Personal Pension Plan v. City and County of San Francisco
Pension plan does not have standing to sue for refund of fraud penalties paid by its trustee.
Taxation Nov. 3, 2005
Borders Online v. State Board of Equalization
State Board of Equalization properly determined that online bookstore was required to collect use tax from its California customers.
Taxation Sep. 26, 2005
Olen Commercial Realty Corp. v. County of Orange
Assessor properly used 'comparable sales' method to determine value of improved property.
Taxation Aug. 19, 2005
Davis v. Commissioner of Internal Revenue
Surviving spouse with limited interest in deceased's trust cannot claim marital deduction on estate tax.
Taxation Aug. 9, 2005
River City Ranches #1 Ltd. v. Commissioner of Internal Revenue
Sheep-breeding partnerships were not entitled to tax deductions for losses due to theft.
Taxation Jul. 26, 2005
Grable & Sons Metal Products Inc. v. Darue Engineering & Manufacturing
National interest in providing federal forum for federal tax litigation is sufficiently substantial to support exercise of federal-question jurisdiction.
Taxation Jun. 15, 2005
Neufeld v. State Board of Equalization
Penalty against taxpayer for filing frivolous claim is constitutional.
Taxation Apr. 12, 2005
Independent Energy Producers Association Inc. v. State Board of Equalization
Electric generation facilities constitute public utilities and are subject to unit taxation.
Taxation Apr. 7, 2005
Aloe Vera of America Inc. v. United States
Party that failed to comply with court's directions in drafting protective order is subject to sanctions.
Taxation Mar. 23, 2005
Ballard v. Commissioner of Internal Revenue
Report of special trial judges in tax cases cannot be excluded from appellate record.
Taxation Mar. 15, 2005
Pillsbury Co. v. Franchise Tax Board
State did not adopt federal tax provision that permits company to assign income to subsidiary to avoid franchise tax.
Taxation Feb. 14, 2005
Opinion of Lockyer
Benefits plan approved by voters prior to July 1978 is not subject to one percent property tax limitation of state constitution.
Taxation Feb. 10, 2005
Commissioner of Internal Revenue v. Banks
Litigant's taxable income includes attorney's contingent-fee.
Taxation Feb. 10, 2005