SIMONS, J.
This matter has been remanded by the Supreme Court (S136922) with directions to vacate our previous decision (The Limited Stores, Inc. v. Franchise Tax Board (July 28, 2005, A102915), 2005 WL 1785249 [nonpub. opn.]) and reconsider the cause in light of Microsoft Corp. v. Franchise Tax Bd. (2006)
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