FUJITSU IT HOLDINGS, INC., Plaintiff and Appellant,
v.
FRANCHISE TAX BOARD, Defendant and Appellant.
Court of Appeals of California, First District, Division Two.https://leagle.com/images/logo.png
July 7, 2004.
Rehearing Denied July 27, 2004.
Review October 20, 2004.
Attorney(s) appearing for the Case
McDermott, Will & Emery, David L. Larson, Palo Alto, John G. Ryan and Lisa Sattler Blackburn, Menlo Park, for Plaintiff and Appellant.
Bill Lockyer, Attorney General of the State of California, Randall P. Borcherding, Supervising Deputy Attorney General, Kristian D. Whitten, Deputy Attorney General, for Defendant and Appellant.
Court of Appeals of California, First District, Division Two.
RUVOLO, J.
I.
INTRODUCTION
Amdahl Corporation (Amdahl),1 a multinational business, sought a refund of $3,390,388 in taxes arising from assessments by the Franchise Tax Board (FTB) for the tax years 1988, 1989, 1991 and 1992. In the underlying tax refund action, Amdahl alleged that the FTB improperly assessed taxes against it for these years based on its erroneous treatment of dividends distributed by Amdahl's first...
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