California Supreme Court Watch

#26-131 Garcia-Rojas v. Franchise Tax Bd., S297035. (A172054; 120 Cal.App.5th 347; San Francisco County Superior Court; CGC23606654.) Petition for review after the Court of Appeal reversed the judgment in a civil action and remanded for further proceedings. This case presents the following issue: Can a nonresident’s business qualify as a “unitary business” for the purpose of calculating state income taxes (Cal. Code Regs, tit. 18, § 17951-4, subd. (c)) if the business is conducted as a single sole proprietorship?

Petition for review granted: 9/03/2026

See the Court of Appeal Opinion.