California Court of Appeal

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Toys "R" Us, Inc. v. Franchise Tax Bd., C045386

Judgment for Franchise Tax Board on plaintiff's complaint for a tax refund is affirmed over a claim that the trial court erred in holding that the term "gross receipts" in Revenue and Taxation Code section 25120(e) could not be construed to include the return of working capital from plaintiff's investment in short-term financial instruments, and the inclusion of the gross receipts would not fairly represent the extent of the corporation's business in the state.

Appellate Information

  • Decided 04/05/2006
  • Published 04/05/2006


  • RAYE, J.


  • California Court of Appeal


  • For Appellant:
  • Morrison & Foerster, Eric J. Coffill, and Carley A. Roberts, Sacramento, for Plaintiffs and Appellants.

  • For Appellees:
  • Bill Lockyer, Attorney General, Lawrence K. Keethe, Supervising Deputy Attorney General, and Michael J. Cornez, Deputy Attorney General, for Defendant and Respondent.
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