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FIRST AMERICAN TITLE INS. CO. v. CALIFORNIA DEPT. OF TAX & FEE ADMINISTRATION

No. D077970.

71 Cal.App.5th 603 (2021)

FIRST AMERICAN TITLE INSURANCE COMPANY, Plaintiff and Respondent, v. CALIFORNIA DEPARTMENT OF TAX AND FEE ADMINISTRATION, Defendant and Appellant.

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

November 12, 2021.

Attorney(s) appearing for the Case

Matthew Rodriguez , Acting Attorney General, Tamar Pachter , Assistant Attorney General, Lisa W. Chao and Van-Dzung V. Nguyen , Deputy Attorneys General, for Defendant and Appellant.

Bewley, Lassleben & Miller, Joseph A. Vinatieri and Leighton M. Anderson for Plaintiff and Respondent.

OPINION

Albert Einstein reportedly said, "The hardest thing in the world to understand is the income tax."1 The subject of this case—sales and use tax as applied to a title insurance company's lease of business equipment—is perhaps a not too distant second.

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