J.C. PENNEY INS. CO. v. STATE BD. OF EQUALIZATION

Docket No. 53393.

94 Cal.App.3d 685 (1979)

157 Cal. Rptr. 1

J.C. PENNEY INSURANCE COMPANY, Plaintiff and Respondent, v. STATE BOARD OF EQUALIZATION, Defendant and Appellant.

Court of Appeals of California, Second District, Division Five.

June 29, 1979.


Attorney(s) appearing for the Case

COUNSEL

George Deukmejian, Attorney General, Ernest P. Goodman, Assistant Attorney General, Philip C. Griffin and Herbert A. Levin, Deputy Attorneys General, for Defendant and Appellant.

Sheppard, Mullin, Richter & Hampton, Allan I. Grossman and John Henry Andrew for Plaintiff and Respondent.


OPINION

STEPHENS, J.

(1a) The question presented here is whether two rooms (360 square feet) out of a total building area of 1,038,586 square feet are a "home office" or "principal office" in this state, thereby allowing a deduction for taxes paid on the whole of such property under former California Constitution, article XIII, section 28, subdivision (e) (1), and former...

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