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Gilbert v. U.S.
District court was correct that it lacked subject matter jurisdiction over plaintiffs' suit for declaratory judgment related to federal tax obligations. 		Tax 9th May 21, 2021
Patients Mutual Assistance Collective v. Commissioner of Internal Revenue
Tax Court did not err in concluding that plaintiff's inventory cost is determined by Treas. Reg. Section 1.471-3(b), which applies to purchaser and reseller of the products it sells. 		Tax 9th Apr. 23, 2021
Silva v. Humboldt County
County's measure amendments impermissibly broadened scope of tax by imposing taxes on property owners subject to commercial marijuana cultivation permit regardless of whether they cultivated marijuana. 		Tax 1DCA/1 Apr. 8, 2021
U.S. v. Boyd
31 U.S.C. Section 5321(a)(5)(A) authorizes IRS to impose only one non-willful penalty when an untimely, but accurate, Foreign Bank and Financial Accounts form is filed, no matter number of accounts. 		Tax 9th Mar. 25, 2021
Modification: LA Live Properties, LLC v. County of Los Angeles
Trial court correctly concluded that plaintiff's claim for refund of property taxes was not reviewable on the merits because plaintiff did not exhaust its administrative remedies. 		Tax 2DCA/3 Mar. 19, 2021
Modification: Ashford Hospitality v. City and County of San Francisco
Trial court properly concluded that defendant's transfer tax did not violate Equal Protection Clause. 		Tax 1DCA/4 Mar. 10, 2021
Ashford Hospitality v. City and County of San Francisco
Trial court properly concluded that defendant's transfer tax did not violate Equal Protection Clause. 		Tax 1DCA/4 Mar. 3, 2021
LA Live Properties, LLC v. County of Los Angeles
Trial court correctly concluded that plaintiff's claim for refund of property taxes was not reviewable on the merits because plaintiff did not exhaust its administrative remedies. 		Tax 2DCA/3 Mar. 2, 2021
Modification: Howard Jarvis Taxpayers Assn. v. City and County of San Francisco
Proposition 13 did not compel a two-thirds supermajority vote to approve voter initiatives. 		Tax 1DCA/5 Feb. 24, 2021
Howard Jarvis Taxpayers Assn. v. City and County of San Francisco
Proposition 13 did not compel a two-thirds supermajority vote to approve voter initiatives. 		Tax 1DCA/5 Jan. 29, 2021
Chinese Theatres, LLC v. County of Los Angeles
Property owner not entitled to attorney fees under Revenue and Taxation Code Section 1611.6 because trial court did not order County Assessment Appeals Board to make new findings on remand. 		Tax 2DCA/3 Jan. 6, 2021
Phillis v. County of Humboldt
Foreclosure sales are not 'open market transactions' supporting application of Revenue and Taxation Code Section 110's purchase price presumption as measure of value. 		Tax 1DCA/2 Jan. 5, 2021
Letterman Digital Arts Ltd. v. City and County of San Francisco
Trial court properly sustained without leave to amend city's demurrer because taxes and fees plaintiff paid to city did not contravene provisions of Presidio Trust Act. 		Tax 1DCA/4 Jan. 4, 2021
Prang v. Amen
Respondent's petition for writ of administrative mandate was properly granted because 'stock' under Revenue and Taxation Code Section 62(a)(2) applies to all classes of stock, including both voting and non-voting stock. 		Tax 2DCA/5 Dec. 8, 2020
Humphreville v. City of Los Angeles
City's ongoing practice of transferring surplus from Department of Water and Power's revenue fund to City's General Fund did not constitute tax. 		Tax 2DCA/2 Dec. 7, 2020
Mahon v. City of San Diego
City's 'Undergrounding Surcharge' was compensation validly given in exchange for franchise rights and thus was not a tax subject to voter approval under Proposition 218. 		Tax 4DCA/1 Nov. 25, 2020
U.S. v. Allahyari
District court erred by holding that defendant's 2005 deed of trust was not entitled to priority over later-recorded federal tax liens. 		Tax 9th Nov. 16, 2020
Manson Construction Co. v. County of Contra Costa
Vessel Use Exemption to property taxation did not apply to plaintiff's vessels, which were not 'engaged in the transportation of freight' within the meaning of the exemption. 		Tax 1DCA/3 Nov. 4, 2020
U.S. v. Sanmina Corp.
District court did not clearly err in concluding that appellant expressly waived attorney-client privilege by disclosing memoranda to its attorney for purpose of obtaining non-legal valuation analysis. 		Tax 9th Aug. 10, 2020
Wilde v. City of Dunsmuir
City's water rates fall within exemption for tax levies under Article II, Section 9(a) of California Constitution and therefore were not subject to referendum process. 		Tax CASC Aug. 4, 2020
Church v. San Mateo County Assessment Appeals Bd.
Trial court erroneously rejected appeals board's determination that additional costs identified by county assessor should not have been included in assessing value of appellant's property for purposes of property tax. 		Tax 1DCA/4 Jul. 20, 2020
BNSF Railway v. Oregon Dep't of Revenue
Under 49 U.S.C. Section 11501(b)(4), railroads may challenge discriminatory property taxes--even those masquerading as tax exemptions. 		Tax 9th Jul. 9, 2020
Steuer v. Franchise Tax Board
Entire amount of trust income derived from California sources may be taxed regardless of trust fiduciaries' residency. 		Tax 1DCA/3 Jul. 2, 2020
Organic Cannabis Foundation v. Commissioner of Internal Revenue
Petitions could not be deemed timely under Internal Revenue Code mailbox rule because particular FedEx service used was not on IRS's formal list of designated delivery services. 		Tax 9th Jun. 19, 2020
California Dept. of Tax and Fee Administration v. Superior Court (Kintner)
Government Code Section 11350 does not create exemption to Article XIII, Section 32 of California Constitution's requirement that taxpayers pay tax before they can challenge its assessment. 		Tax 2DCA/2 May 11, 2020
County Inmate Telephone Service Cases
Inmates in county jails did not have standing to sue for unlawful taxes paid by telecommunications companies, which passed on that cost to inmates. 		Tax 2DCA/1 Apr. 30, 2020
Badgley v. U.S.
When a grantor derives substantial present economic benefit from property, she retains the enjoyment of that property for purposes of 26 U.S.C. Section 2036(a). 		Tax 9th Apr. 29, 2020
Los Angeles Leadership Academy v. Prang
Charter Schools Act does not suggest that charter schools are to be treated as public school districts for taxation purposes. 		Tax 2DCA/8 Mar. 12, 2020
HGST, Inc. v. County of Santa Clara
Revenue and Taxation Code Section 531.4 mandates assessment as required by law of any portion of property which is wholly or partly inaccurately reported. 		Tax 6DCA Mar. 2, 2020
Altera Corp. v. Commissioner of Internal Revenue
Dissent to en banc denial found Treasury's explanation for decision lacked evidentiary support, and majority's decision potentiated a circuit split while inviting uncertainty for businesses relying on the well-settled 'arm's length' standard. 		Tax 9th Nov. 13, 2019
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