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WILSON v. FRANCHISE TAX BD.

Docket No. B073188.

20 Cal.App.4th 1441 (1993)

25 Cal. Rptr.2d 282

MARC D. WILSON et al., Plaintiffs and Respondents, v. FRANCHISE TAX BOARD, Defendant and Appellant.

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

December 13, 1993.

Attorney(s) appearing for the Case

COUNSEL

Daniel E. Lungren, Attorney General, Edmond B. Mamer and Jack T. Kerry, Deputy Attorneys General, for Defendant and Appellant.

Staker & Gose, Gose, Panitz & Lechman and Philip Garrett Panitz for Plaintiffs and Respondents.

OPINION

ORTEGA, J.

During 1984-1986, plaintiff Marc D. Wilson played quarterback for the Los Angeles Raiders. In the off-season during those years, Wilson lived in Washington State and thus was not a California resident for California income tax purposes. However, because Wilson's income from his Raiders contract derived from a California source, he paid California income tax on a...

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