Defendant board appeals from judgment directing refund of franchise taxes paid under protest for the years 1951 and 1952.
Plaintiff is engaged in the "small loan" or "consumer loan" business. In 1951 it had 423 branch offices, and in 1952, 427 branches, operating in 28 states and Canada. In each year it had 33 offices in California.
Plaintiff's general administrative offices are located...
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