California Tax Appeals Office Rejects Unitary Business Treatment of Division Sale Gain
The Office of Tax Appeals found a beverage distribution division was not unitary with the taxpayer's other divisions, making the sale gain nonbusiness income not apportionable to California.
2 reports on this incident · first at Sep 10, 2026, 4:17 p.m. ET
Earlier reports
Sep 10, 2026, 4:17 p.m. ETFirst report
California Tax Appeals Office Rejects Unitary Business Treatment of Division Sale Gain
The California Office of Tax Appeals has ruled that a beverage distribution division was not unitary with the taxpayer's other divisions, meaning income from its sale was nonbusiness income not apportionable to California, according to natlawreview.com. The taxpayer is an S corporation.
The California Franchise Tax Board had asserted that the taxpayer was engaged in a single unitary business across all 14 divisions, and that the income from the sale was therefore business income apportionable to California, natlawreview.com reported. The Office of Tax Appeals rejected that position, and also rejected the FTB's tax benefit rule argument, according to the report.
The matter was an administrative proceeding before the Office of Tax Appeals, natlawreview.com reported.
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- Version 110 Sept 2026, 20:23current
First published.
- Version 110 Sept 2026, 20:17current
First published.
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