Pillsbury Is Victorious in Longstanding California Personal Income Tax Case

The California Office of Tax Appeals (OTA) recently reversed in its entirety a proposed assessment of more than $3 million in California personal income tax, interest and penalties which was issued to an Australian couple in 2012. The case involved the sale by the husband of an Australian software company which he co-founded to Adobe Systems in 2009. The issue was how much tax should be owed to the State of California on that sale. Pillsbury was engaged in 2014 to handle the case and after 8 years before the Franchise Tax Board and the OTA, was successful in convincing the OTA that its clients had properly filed their California return. Specifically, Pillsbury was able to prove that its clients were entitled to a stepped-up basis in the company’s shares which completely eliminated the proposed assessment.