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action agreement allocation amendment amount Angeles Appellant Appellant's applied Attorney authority basis Board of Equalization California cent City claim commerce clause Company compilation divisions Constitution contention contract Corporation Franchise Tax Counsel County Cumulative Indexes last deduction Deere & Company defendant determination District erty exemption fact Federal filed Franchise Tax Act Franchise Tax Board Franchise Tax Commissioner gross income gross receipts held hospital imposed included Indexes last pages interest interstate commerce involved jobbing house judgment Legislature levied liability license tax McColgan ment operation opinion ordinance overpayment owner pages of compilation paid payment period Personal Income Tax plaintiff prior purchase purposes question received refund Report Respondent retail Revenue and Taxation rule sales tax statute supra Supreme Court tangible personal property taxable Taxation Code taxpayer thereof tion trial court trust trust instrument trustor United