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AETNA LIFE INS. CO. v. STATE BD. OF EQUALIZATION

Docket No. A055691.

11 Cal.App.4th 1207 (1992)

15 Cal. Rptr.2d 26

AETNA LIFE INSURANCE COMPANY, Plaintiff and Appellant, v. STATE BOARD OF EQUALIZATION, Defendant and Respondent.

Court of Appeals of California, First District, Division Four.

December 21, 1992.

Attorney(s) appearing for the Case

COUNSEL

McCutchen, Doyle, Brown & Enersen, John B. Lowry and David M. Heilbron for Plaintiff and Appellant.

Daniel E. Lungren, Attorney General, Timothy G. Laddish, Assistant Attorney General, Richard F. Finn and Jack Newman, Deputy Attorneys General, for Defendant and Respondent.

OPINION

REARDON, J.

Appellant Aetna Life Insurance Company (Aetna) paid $18.4 million in disputed taxes and sued to recover this sum, plus interest. The trial court entered judgment for respondent State Board of Equalization (the Board), from which Aetna appeals, contending that it was unlawfully taxed on premiums it never received.

I. FACTS

Aetna is a Connecticut corporation doing business in California. In the...

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