• Franchise Tax Board's Attempt to Apply Expense Attribution is Soundly Rejected
  • January 12, 2006 | Author: Jeffrey M. Vesely
  • Law Firm: Pillsbury Winthrop Shaw Pittman LLP - San Francisco Office
  • In a significant taxpayer victory involving expense attribution issues, the California State Board of Equalization ("SBE"), in the Appeal of Beneficial California, Inc., No. 203445, CCH California Tax Rptr. ΒΆ 403-851, rejected the Franchise Tax Board's ("FTB") attempt to disallow interest expense deductions solely because the taxpayer received deductible dividends from an insurance affiliate.