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GENERAL MILLS, INC. v. FRANCHISE TAX BD.

No. A131477.

208 Cal.App.4th 1290 (2012)

146 Cal. Rptr. 3d 475

GENERAL MILLS, INC., et al., Plaintiffs and Appellants, v. FRANCHISE TAX BOARD, Defendant and Respondent.

Court of Appeals of California, First District, Division Five.

August 29, 2012.

Attorney(s) appearing for the Case

Morrison & Foerster, Andres Vallejo , Scott M. Reiber , Paul H. Frankel and Miriam A. Vogel for Plaintiffs and Appellants.

Kamala D. Harris , Attorney General, Paul D. Gifford , Assistant Attorney General, and Joyce E. Hee , Deputy Attorney General, for Defendant and Appellant.

OPINION

BRUINIERS, J. —

Under California's version of the Uniform Division of Income for Tax Purposes Act (UDITPA; Rev. & Tax. Code, § 25120 et seq.),1 the portion of a national or multinational company's income that is subject to taxation in this state is determined by a formula that compares the company's payroll, property and sales in this...

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